Law Updates

Subject

Summary: The State Pollution Control Board, Odisha , issued Public Notice No. 11208/IND-I-SWM-Misc-152(2025-26) on 23 July 2026 concerning compliance with the Environment Protection (End-of-Life Vehicles) Rules, 2025. The Odisha ELV EPR registration notice 2026 calls upon producers, Registered Vehicle Scrapping Facilities and bulk consumers operating in the state to register through the Central Pollution Control Board's centralised ELV Extended Producer Responsibility portal within three months. It also directs them to make a hard-copy submission to the Odisha Board. The notice is relevant to vehicle manufacturers, assemblers, sellers and importers that fall within the Rules' definition of “producer” registered vehicle scrapping facilities and fleet-owning bulk consumers. It also restates duties for registered vehicle owners, collection centres and automated testing stations. The central Rules were notified by the Ministry of Environment, Forest and Climate Change through S.O. 98(E) dated 6 January 2025 and came into force on 1 April 2025. The Odisha notice does not create the entire ELV framework afresh. It is a state-level compliance and enforcement communication requiring covered entities operating in Odisha to complete registration and follow the existing Rules. Particular Verified details Issuing authority State Pollution Control Board, Odisha, under the Department of Forest, Environment and Climate Change, Government of Odisha Document type Public notice and state-level compliance direction Date of issue 23 July 2026 Date of publication Not expressly specified in the notice the official file is hosted in the Odisha SPCB's July 2026 web directory Governing rules Environment Protection (End-of-Life Vehicles) Rules, 2025 Rules' effective date 1 April 2025 Main entities addressed Producers, Registered Vehicle Scrapping Facilities and bulk consumers operating in Odisha Core direction Register on the centralised online ELV EPR portal and submit a hard copy to the Odisha SPCB Time allowed by notice “Within 3 months” the starting point is not separately stated Indicative date if counted from notice date 23 October 2026, subject to confirmation from the Odisha SPCB Transition period No separate transition period is expressly specified in the notice Portal CPCB EPR ELV portal Enforcement warning Action considered appropriate, including environmental compensation, may be initiated for default under the applicable framework The issue date, the Rules' commencement date and the state registration direction are different dates. Businesses should not treat 23 July 2026 as the commencement of the national Rules those Rules have applied since 1 April 2025. The Regulatory Framework The Ministry of Environment, Forest and Climate Change made the Environment Protection (End-of-Life Vehicles) Rules, 2025 by exercising powers under the Environment (Protection) Act, 1986 and the Environment (Protection) Rules, 1986. The Rules establish an Extended Producer Responsibility system for vehicles and set duties for producers, registered owners, bulk consumers, Registered Vehicle Scrapping Facilities, collection centres, automated testing stations, CPCB, State Boards and state governments. The framework operates alongside the Motor Vehicles Act, 1988, the Central Motor Vehicles Rules, 1989 and the Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules, 2021. A vehicle becomes an End-of-Life Vehicle according to the vehicle-scrapping framework referred to in the 2025 Rules the Odisha notice does not create a separate definition. CPCB administers the centralised online system and registers producers. State Pollution Control Boards use the same portal to register RVSFs and bulk consumers and receive their returns. The Rules also connect environmental compliance with vehicle fitness testing, authorised scrapping, material recovery, hazardous-waste disposal and EPR certificates. The attached notice is therefore best classified as a public notice covering registration, reporting and enforcement under an existing national framework. It is not an amendment to S.O. 98(E), a new set of rules or an extension of the 1 April 2025 commencement date. Why This Was Implemented? The Odisha notification makes it quite clear that its objective is to notify the regulated parties and get them into compliance with the 2025 Rules. This objective is achieved through the following measures contained in the compliance mechanism: identification of obligated producers, fleet owners, and scrapping facilities transition of registration and returns to one centralized portal association of vehicle fitness data with ELV management channelling of ELVs to either Registered Vehicle Scrapping Facilities or collection points accounting of recovered steel and other material flows certification of extended producer responsibility target attainment using EPR certificates and allowing environmental compensation where specified non-compliance causes environmental or public-health harm. These are purposes of the verified regulatory framework. They should not be read as a claim that every operational outcome has already been achieved. Scope and Applicability The 2025 Rules apply to all types of vehicles covered under the definition of Section 2(28) of the Motor Vehicles Act, 1988, such as electric vehicles, battery-run vehicles, e-rickshaws, and e-carts. Agricultural tractors, agricultural trailers, combine harvesters, and power tillers. The Rules apply to producers, registered vehicle owners, bulk consumers, RVSFs, collection centres, automated testing stations, and entities involved in testing, handling, processing, and scrapping ELVs The Odisha notice's three-month registration direction specifically names producers, RVSFs and bulk consumers operating in Odisha. Stakeholder or product Covered? Relevant condition Main responsibility Producer Yes Manufactures or assembles and sells vehicles under its brand, sells under its brand vehicles made by others, or imports vehicles CPCB registration, EPR targets, annual return and other producer duties RVSF Yes Operates as a Registered Vehicle Scrapping Facility State Board registration, environmentally sound scrapping, records and quarterly returns Bulk consumer Yes Owns more than 100 vehicles, including a State transport undertaking State Board registration, timely ELV deposit and annual return Registered vehicle owner Yes Vehicle is registered in that person's name Fitness testing and ELV deposit within the prescribed period Collection centre Yes Receives or stores ELVs under the applicable framework Safe handling, transfer to RVSF and records Automated testing station Yes Declares vehicles unfit under the Central Motor Vehicles Rules Upload unfit-vehicle details to the portal Electric or battery-operated vehicle Yes Falls within the Rules' vehicle definition Subject to ELV framework, with specified waste streams governed separately Agricultural tractor, agricultural trailer, combine harvester or power tiller No Expressly excluded from the 2025 Rules Not covered by these Rules Waste batteries, plastic packaging, waste tyres, used oil and e-waste are carved out to the extent that their respective waste-management rules govern them. This does not remove the vehicle itself from ELV regulation it separates specified waste streams into their applicable regimes. Implementation Timeline and Compliance Calendar Event or requirement Date or frequency Affected entity Required action National notification issued 6 January 2025 All covered stakeholders Review S.O. 98(E) and determine applicability ELV Rules commenced 1 April 2025 All covered stakeholders Comply with the 2025 Rules Current-year EPR obligation declaration By 30 April each year Producer Declare current-year EPR obligation to CPCB Producer annual return By 30 June each year Producer File Form 1 for the previous financial year Bulk-consumer annual return On or before 30 June each year Bulk consumer File Form 2 for the previous financial year RVSF quarterly return By the 30th day of the month following the previous quarter RVSF File Form 3 and keep supporting records Odisha public notice issued 23 July 2026 Entities operating in Odisha Review registration and filing status State notice registration period Within three months Producers, RVSFs and bulk consumers in Odisha Complete portal registration and hard-copy submission Indicative three-month date 23 October 2026, if counted from 23 July 2026 Same entities Treat as a planning date and confirm with Odisha SPCB Deposit of an ELV Within 180 days from the date the vehicle becomes an ELV Registered owner or bulk consumer Deposit at an eligible sales outlet, collection centre or RVSF The key point that comes up in relation to Odisha specifically is that of three months. Since there is no separate mention of the date from which the period will commence, it would be better if the entities get a written clarification of the same. What Has Changed? The national obligations have existed since the Rules came into force on 1 April 2025. The main development is the Odisha Board's state-level direction calling for registration and a hard-copy submission within three months, backed by an enforcement warning. Compliance area Earlier governing position Odisha notice position Practical meaning Producer registration Producer applies in Form 4 to CPCB through the portal Producers operating in Odisha are told to register within three months Unregistered producers should regularise their status promptly RVSF registration RVSF applies in Form 5 to the State Board through the portal RVSFs operating in Odisha are told to register within three months Portal and state-level registration status should be checked Bulk-consumer registration Bulk consumer applies in Form 6 to the State Board through the portal Bulk consumers operating in Odisha are told to register within three months Fleet ownership must be assessed against the “more than 100 vehicles” threshold Physical submission Not detailed in the notice's summary of the central Rules Hard-copy submission to Odisha SPCB is directed The exact hard-copy contents and procedure require confirmation Enforcement The Rules allow registration action, inspection, audit and environmental compensation in specified cases Odisha SPCB warns that appropriate action may be initiated for default Evidence of registration, filings and operational compliance should be organised The notice should not be described as creating a new nationwide EPR regime or changing the national EPR target schedule. Who Must Register on the CPCB ELV EPR Portal? The Odisha notice names three categories: producers, Registered Vehicle Scrapping Facilities, and bulk consumers operating in Odisha. The Rules use one central portal but allocate the registering authority differently. Entity Application form under the Rules Registering authority Portal route Producer Form 4 Central Pollution Control Board Centralised online portal Registered Vehicle Scrapping Facility Form 5 Concerned State Pollution Control Board Centralised online portal Bulk consumer Form 6 Concerned State Pollution Control Board Centralised online portal A producer includes an entity that manufactures or assembles and sells vehicles under its own brand, sells under its brand vehicles produced by another manufacturer or supplier, or imports vehicles. A bulk consumer means a consumer owning more than 100 vehicles and includes a State transport undertaking. The Rules provide for issuance of registration certificates within 15 days of receipt of the application. Registration remains valid until suspended or cancelled. These provisions do not remove the need to answer portal objections or supply accurate information. State-Specific Registration Direction and Deadline The notification is to those obligated entities that have been “operating in the State of Odisha” and must register in three months. It does not provide any additional separate date for its final period and does not state anything about being “three months from the date of this notification.” For internal planning purposes, companies can take three months from 23 July 2026, making the tentative date 23 October 2026. As implied in the notice, when this period begins, the date needs to be confirmed with the Odisha SPCB. It would not be wise to postpone the overdue registration process. Hard-Copy Submission to the State Pollution Control Board The notice requires a hard-copy submission to the State Pollution Control Board, Odisha, in addition to portal registration. It does not expressly specify: whether the hard copy must contain the full application, portal acknowledgement, registration certificate or another record the supporting-document list whether producers and State Board registrants must submit different sets the physical submission address or permitted delivery method whether an acknowledgement will be issued or whether the hard copy must be submitted before, with or after portal approval. A safe approach is to obtain written procedural confirmation from the Board and retain proof of dispatch or receipt. Businesses should not rely on a generic document checklist that has not been issued for this notice. Stakeholder-Wise ELV Compliance Matrix Stakeholder Registration or portal duty Operational duty Return or record duty Deadline or frequency Main compliance risk Producer Register with CPCB in Form 4 Meet EPR targets use registered entities to support collection Form 1 annual return and current-year obligation declaration 30 June and 30 April respectively EPR shortfall or engagement with unregistered entities RVSF Register with State Board in Form 5 Depollute, dismantle, segregate, recover and route residues lawfully Form 3 quarterly return and material records 30th day of next month after each quarter Incomplete mass balance or unlawful downstream transfer Bulk consumer Register with State Board in Form 6 Test vehicles and deposit ELVs within 180 days Form 2 annual return On or before 30 June Threshold misclassification or retained ELVs Registered owner No ELV portal registration is required merely because of ownership Test and deposit ELV within 180 days Keep practical transfer evidence Vehicle-specific Retaining an ELV beyond permitted period Collection centre No separate portal-registration duty stated in this notice Collect, store safely and send ELVs to RVSF Receipt, transfer and handling records Ongoing Poor traceability or unsafe storage Automated testing station Upload unfit vehicle details Conduct functions under vehicle-testing framework Portal data As vehicles are declared unfit Missing or inaccurate uploads Responsibilities of Vehicle Owners Every registered owner and bulk consumer must ensure that the vehicle is tested in accordance with section 56 of the Motor Vehicles Act, 1988 and rule 52 of the Central Motor Vehicles Rules, 1989. Once the vehicle becomes an ELV under the referenced vehicle-scrapping framework, it must enter an authorised collection or scrapping route. The owner may deposit the ELV at a producer's designated sales outlet, a designated collection centre or an RVSF. The Rules do not require an ordinary registered owner to register on the ELV EPR portal merely because the person owns a vehicle. Responsibilities of Collection Centres Collection centres must collect and store ELVs, handle them in an environmentally sound manner and send them to an RVSF. They must keep records of ELVs received, ELVs sent to an RVSF and the manner in which those vehicles were handled. The Odisha notice does not create a separate collection-centre registration process. A collection centre should nevertheless verify its legal relationship with the producer or RVSF and maintain a clear vehicle-level chain of custody. Role of Automated Testing Stations An automated testing station must upload details of vehicles declared unfit under rule 182 of the Central Motor Vehicles Rules, 1989 to the centralised portal. Upload may occur directly or by linking the Central Government's electronic portal established under rule 181(1). This reporting function helps connect fitness outcomes with ELV compliance. It does not authorise the testing station to scrap vehicles unless the station separately holds the required status and approvals. Obligations of Bulk Consumers A bulk consumer owns more than 100 vehicles the threshold is not “100 or more.” State transport undertakings are included. A covered fleet owner must: obtain registration from the State Board through the centralised online portal ensure vehicles undergo the prescribed fitness testing deposit each ELV at an eligible destination within 180 days of it becoming an ELV avoid retaining the ELV beyond that period and file Form 2 on or before 30 June for the previous financial year. Form 2 seeks fleet and ELV information, including vehicles registered, specified age-related details, fit vehicles, unfit or end-of-life vehicles, and vehicles deposited for scrapping. Fleet data should therefore be reconciled before filing. Producer Extended Producer Responsibility and Scrapping Targets Producers must fulfil EPR for vehicles introduced in the domestic market, including vehicles put to self-use. They must meet category-specific scrapping targets in the Schedule and fulfil EPR through certificates generated by their own RVSF or another qualifying RVSF. For financial year 2025-26, the Schedule sets a minimum target of 8% of the steel used in non-transport vehicles placed in the market in 2005-06 and 8% of the steel used in transport vehicles placed in the market in 2010-11. For 2026-27, the minimum remains 8%, using 2006-07 as the base year for non-transport vehicles and 2011-12 for transport vehicles. Later years use the relevant historical base years and higher percentages according to the Schedule. Up to 30% of an annual target may be carried forward for compliance over the next four years. EPR target calculation under these Rules concerns steel scrapping. Batteries, waste tyres and used oil remain governed under their respective waste-management frameworks. Producers should not use that target basis to ignore other ELV material-handling duties. Producer Take-Back, Buy-Back, Deposit-Refund and Awareness Measures The Rules require producers to take measures that encourage safe ELV deposit. They may deploy a buy-back scheme, deposit-refund scheme or another arrangement and may designate a registered entity to help fulfil EPR. Producers must also arrange to receive ELVs through designated collection centres, including sales outlets publish the list on their website and at prominent places at sales and service centres provide the list to CPCB through the portal and conduct awareness campaigns. The Rules give flexibility in scheme design but do not make one named scheme the only permitted route. Annual Returns for Producers and Bulk Consumers Filer Form Recipient or portal route Frequency Due date Main information Producer Form 1 Centralised portal to CPCB Annual 30 June for previous financial year Vehicle numbers and types, steel weight, self-use vehicles and EPR fulfilment Bulk consumer Form 2 Centralised portal to State Board Annual On or before 30 June for the previous financial year Fleet details and ELVs deposited for scrapping The producer must separately declare the current year's EPR obligation by 30 April of the same year. Registration does not replace return filing, and a return does not cure a missing registration. Responsibilities of Registered Vehicle Scrapping Facilities An RVSF must receive unfit vehicles and ELVs and undertake treatment, depollution, dismantling, segregation and scrapping according to applicable law. It must register with the concerned State Board in Form 5 and maintain complete material and destination records. Environmentally Sound Depollution, Dismantling and Material Handling The Rules require treatment involving depollution and collection of liquids, gases, catalysts, mercury-containing parts, batteries and hazardous waste. They also require dismantling, segregation, safe storage of different waste categories in separate bins, and recycling or refurbishment of materials such as plastic, metals, tyres, catalytic converters, magnets, batteries and e-waste. Separate waste regimes continue to apply to specified materials. RVSFs should map each output stream to the correct authorised recipient and retain evidence of quantity and handover. Downstream Transfer to Recyclers, Refurbishers and Co-Processors Where the RVSF does not have its own recycling or refurbishing facility, recovered and segregated materials must be sent to registered recyclers or refurbishers or to co-processors for recycling and reuse. The facility should verify the status of each downstream party rather than rely only on a commercial invoice. Disposal of Hazardous and Non-Recyclable Residues Non-recyclable or non-refurbishable material and non-utilisable hazardous material must be sent to a Common Hazardous Waste Treatment, Storage and Disposal Facility authorised under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The Odisha notice does not set storage periods, transport-document requirements or treatment charges. Those details must be determined from the applicable waste law, authorisations and official directions. Generation, Issuance, Exchange and Purchase of EPR Certificates Stage Responsible entity Verified basis or action Material recovery RVSF Process ELVs and account for steel and other materials Certificate generation basis RVSF data Weight of steel scrap generated, measured in kilograms Certificate issuance CPCB Weight of steel scrap generated, measured in kilograms Purchase Producer Purchase through the portal within current and carried obligations Adjustment Portal mechanism Apply certificates first to earlier obligations Reporting RVSF Record certificate transactions and include them in quarterly returns A used certificate cannot be exchanged again, and a certificate purchased by one producer cannot be transferred to another producer. Certificates generated by RVSFs are valid for five years. Generation is conditional on accounting for other ELV materials and environmentally sound disposal of non-recoverable or hazardous residues. Quarterly Returns for Registered Vehicle Scrapping Facilities An RVSF must file Form 3 on the centralised online portal to the State Board by the 30th day of the month following the previous quarter. The return covers the weight of ELVs received and category-wise material recycled, refurbished, transferred for recycling or refurbishment, processed, or sent to a Common Hazardous Waste Treatment, Storage and Disposal Facility. The facility must also keep supporting records. Portal figures should reconcile with vehicle receipts, weighment records, downstream acknowledgements, waste manifests where applicable, and EPR certificate transactions. Record-Keeping, Portal Reporting and Data Linkage Stakeholder Record or data Destination Timing Producer Market placement, steel weight, self-use vehicles, EPR fulfilment CPCB portal Annual and as obligation declarations require Bulk consumer Fleet, fitness status and ELVs deposited State Board through portal Annual RVSF ELV receipts, output weights, downstream transfers, disposal and certificates State Board through portal Quarterly and ongoing records Collection centre ELVs received, handled and sent to RVSF Internal record produce when required Ongoing Automated testing station Vehicles declared unfit Centralised portal directly or through linkage On declaration or system process Recommended internal controls include portal acknowledgement files, controlled spreadsheets or system records, due-date alerts, authorised-signatory review and periodic reconciliation. These controls support compliance but do not replace the forms prescribed by the Rules. Documents and Records Required Documents or records required are as follows: Form 4 registration application Form 5 registration application Form 6 registration application Form 1 annual return Form 2 annual return Form 3 quarterly return ELV receipt and transfer records Downstream handover records Portal acknowledgements and hard-copy receipt The exact hard-copy pack required by the Odisha notice is not expressly specified. Businesses should not assume this table is itself the Board's hard-copy checklist. Impact on Businesses Vehicle Producers and Importers Producers need clean historical data on vehicle placement and steel weight, a valid portal registration, current-year obligation declarations, annual returns, and enough eligible certificates to meet targets. Procurement and EHS teams must ensure that ELV partners are registered. Registered Vehicle Scrapping Facilities RVSFs face the most detailed operational burden. Vehicle receipt, depollution, material segregation, downstream transfer, hazardous-residue disposal, quarterly reporting, and certificate generation must form one reconcilable record trail. Bulk Consumers and Fleet Operators Fleet owners must first test whether they cross the “more than 100 vehicles” threshold. Covered fleets require State Board registration, vehicle-level fitness and ELV tracking, timely deposit, and an annual Form 2 return. Collection Centres and Testing Stations Collection centres need reliable receipt, storage and transfer controls. Automated testing stations need accurate portal uploads for vehicles declared unfit. Weak data at either point may affect the chain of custody downstream. Challenges and Cost Implications The notice does not prescribe fees or quote compliance costs. Likely cost drivers include portal preparation, historical data cleansing, weighment and material records, authorised downstream services, safe storage, staff time, audit readiness and professional support where needed. Short-term challenges may include identifying the correct entity category, resolving portal data gaps, compiling hard-copy records and reconciling past returns. Ongoing burden will centre on vehicle and material traceability, timely filings and vendor verification. MSMEs operating RVSFs may feel these system and staffing costs more sharply, though the legal duties do not disappear because an entity is small. Benefits for Businesses Effective compliance can provide practical benefits without guaranteeing a commercial outcome: clearer chain of custody for retired vehicles lower risk of dealing with informal or unregistered scrapping channels better material and hazardous-waste accountability stronger audit evidence orderly EPR certificate generation and purchase better fleet retirement data and improved coordination across legal, EHS, operations, procurement and finance teams. Is This a Right Decision or Additional Burden? The direction supports an established environmental objective: ELVs should enter traceable facilities capable of depollution, recovery, and safe residue disposal. Central portal data can help regulators compare vehicle intake, recovered material, returns, and producer obligations. The additional state-level hard-copy direction creates an administrative burden, especially because the required contents and process are not stated. A clear checklist, filing channel, and unambiguous final date would reduce avoidable uncertainty. On balance, registration enforcement is consistent with the Rules, while procedural clarification would make implementation more practical. Business Opportunities Created The framework can create legitimate demand for authorised scrapping capacity, collection networks, material recovery, recycling, refurbishment, hazardous-waste services, compliance systems, portal support and independent record review. Producers may also need better vehicle and steel-data architecture to forecast obligations. These are likely commercial implications, not assured revenue projections. Entry into any activity remains subject to the applicable registration, authorisation, technical and environmental requirements. Business and Regulatory Perspective From a regulatory perspective, registration makes the obligated population visible and enables inspections, returns and EPR certificate controls. From a business perspective, the harder task is not clicking “register” it is building data and operating controls that remain consistent across the portal, physical records and actual ELV movement. The notice therefore deserves attention even from an entity that has already started registration. Businesses should verify whether the registration is active, whether the correct authority is reflected, whether returns are current, and whether the Odisha hard-copy direction has been met. Common Mistakes or Risks to Avoid Treating every owner of 100 vehicles as a bulk consumer when the definition says more than 100. Counting the 180 days from the Odisha notice rather than from the date a vehicle becomes an ELV. Assuming producer registration with CPCB removes the Odisha hard-copy direction. Filing a registration application but overlooking annual or quarterly returns. Using an unregistered entity for ELV scrapping or EPR fulfilment. Treating recovered steel as the only waste stream requiring control. Reporting certificate quantities that do not reconcile with steel recovery and other material records. Inventing a hard-copy document pack instead of obtaining official clarification. Practical Readiness Plan for Producers, RVSFs and Bulk Consumers Conduct an applicability review. Make sure the legal entity, function, vehicle type, fleet size, and Odisha operation linkages are accurate. Verify registration validity. Ensure that there is registration reflected on the portal and whether objections are still pending. Respond to Odisha filing. Get the checklist from the Board in the original and physical copy and file it. Resolve return loopholes. Conduct a review of Form 1, Form 2, or Form 3 filing and current year declarations by the producers. Align operational proof. Align vehicles, dates, weights, destination of materials, and certificates. Audit vendor controls. Ensure that the scrapping and downstream entities have the requisite status for the activity. Get ready for consideration. Have all your registrations, returns, acknowledgements, and operating proof in place. How Can Corpseed Help? Corpseed can support affected businesses with ELV EPR registration services and related compliance work based on the entity's actual role and records. ELV Rules applicability assessment for producers, importers, RVSFs and fleet operators CPCB ELV EPR portal registration support Form 4, Form 5 and Form 6 application-document review Odisha SPCB hard-copy submission coordination after procedural confirmation Form 1, Form 2 and Form 3 filing support ELV compliance-gap and record-traceability assessment EPR certificate and registered-vendor document review Ongoing environmental compliance calendar and audit-readiness support The scope should be fixed after checking the entity category, registration status, portal records, and outstanding filings. Corpseed assists with preparation and coordination but cannot guarantee registration, certificate issuance, regulatory acceptance, or a fixed authority timeline. Businesses covered by the Odisha notice may contact Corpseed for an applicability and filing-status review before completing the portal and physical-submission process.

Subject

Summary: The Ministry of New and Renewable Energy has invited comments from stakeholders on the draft revised specifications for solar pump controllers. The invitation was issued by its Standards and Quality Control Division through Office Memorandum File No. 313-12/2/2026-S&QC, dated 12 August 2026. The draft, prepared by the National Institute of Solar Energy (NISE), proposes detailed performance, safety, testing, and environmental requirements for solar photovoltaic water-pumping controllers. It also introduces a wider role for these controllers by covering multifunction applications, battery storage and grid-interactive operation. According to the office memorandum, comments may be submitted by 28 August 2026. This is a consultation deadline, not a deadline for complying with the proposed technical requirements. The proposal may be particularly relevant to solar pump controller manufacturers, PM-KUSUM vendors, system integrators, component suppliers, battery-system developers, testing laboratories, state implementing agencies and businesses involved in agricultural solar-energy equipment. Draft Specification at a Glance Particular Verified details Issuing authority Ministry of New and Renewable Energy, Standards and Quality Control Division Technical draft prepared by National Institute of Solar Energy Document type Office memorandum inviting comments, accompanied by draft revised technical specifications File number 313-12/2/2026-S&QC Date of issue 12 August 2026 Legal status Draft issued for stakeholder consultation Effective date Not expressly specified Consultation deadline in office memorandum 28 August 2026 Compliance deadline Not applicable at the draft-consultation stage Proposed standard title Solar Photovoltaic Water Pumping Controllers - Performance, Safety and Test Requirements Maximum covered PV input voltage Up to 1,000 V DC Applications covered Agricultural, potable-water, community-water and industrial solar pumping applications Controller modes covered Off-grid, off-grid with storage, multifunction, grid-feeding and grid-interactive Supported motor technologies Induction, PMSM and BLDC motors Main stakeholders Manufacturers, system integrators, testing laboratories, PM-KUSUM vendors and implementing agencies Main development Proposed standardisation of controller safety, efficiency, interoperability, monitoring and testing Fees or penalties Not expressly specified The official MNRE notice confirms that the Ministry has invited comments on the draft. However, the webpage displays an “End Date” of 11 October 2026, while the attached office memorandum expressly asks stakeholders to submit comments by 28 August 2026. Unless MNRE issues a clarification, stakeholders should work with the earlier date stated in the signed office memorandum. Draft Status and Legal Effect These are only proposed requirements at this point. The draft is still open for consultation and does not create any new compliance obligation yet. The draft repeatedly uses expressions such as “shall,” “should” and “may.” These expressions describe how the proposed framework is intended to operate if it is finalised. They do not, by themselves, make the draft legally binding during the consultation stage. The document does not expressly specify: A final adoption date An effective date A transition period A certification commencement date A list of recognised testing laboratories A product-registration process Government fees Enforcement provisions Penalties for non-compliance Treatment of controllers already manufactured, tested or deployed These matters may need to be addressed when MNRE finalises the specification or incorporates it into PM-KUSUM guidelines, procurement documents, quality-control requirements or another binding instrument. Regulatory and Standards Framework The proposal is connected with the technical framework for solar photovoltaic water pumping systems deployed under MNRE programmes, including PM-KUSUM. Existing MNRE specifications for solar photovoltaic water pumping systems already address matters such as controller capacity, MPPT, enclosure protection, remote monitoring and pump-system safeguards. The new draft focuses specifically on solar pump controllers and proposes a more detailed framework for controller performance, safety, environmental resistance, power quality and testing. Normative references The draft identifies the following as normative references, meaning that their relevant provisions are intended to form part of the proposed technical requirements: IS 17018-1 - Solar photovoltaic water pumping systems and centrifugal pumps IS 16221 Part 1 - Safety of power converters used in photovoltaic power systems IS 16221 Part 2 - Safety of power converters used in grid-connected photovoltaic systems IS 16169 - Procedure for islanding-prevention measures IEC 60990:1999 - Touch-current measurement IEC 60529 - Degrees of protection provided by enclosures IS/IEC 61683 - Efficiency measurement of PV power conditioners IEC 62116 - Test procedure for islanding-prevention measures IEC 60068 series - Environmental testing IS 3043 - Code of practice for earthing The draft states that the latest editions of these standards would apply. Informative references The draft separately classifies the following as informative references: MNRE technical specifications for solar water pumping systems IEC 61000-4-7 concerning harmonics and interharmonics measurements IEC 61000-3-2 concerning harmonic-current emission limits An informative reference is included to provide additional context or guidance. It does not, by itself, create a separate requirement that businesses must follow unless the final document specifically makes it mandatory. Scope and Applicability The draft applies to solar photovoltaic water pumping controllers intended for: Off-grid solar pumping Off-grid pumping with battery storage Multifunction operation Grid-feeding operation Grid-interactive pumping systems It covers controllers used for: Agricultural irrigation Potable-water supply Community-water systems Industrial solar pumping The proposed scope extends to controllers with: PV input voltage up to 1,000 V DC Single-phase or three-phase output Compatibility with induction motors Compatibility with permanent magnet synchronous motors Compatibility with brushless DC motors The proposal is therefore wider than a controller specification limited to agricultural irrigation. It could influence product design for community water, rural-energy, industrial pumping and multifunction farm-energy systems. Proposed Controller Configurations The proposed configurations cover different operating needs, from basic solar pumping to battery-backed systems and grid-connected applications: Standard solar pumping controller The core controller converts DC electricity from a solar PV array into an electrical output suitable for operating a pump motor. It is also expected to perform control, protection, MPPT and monitoring functions. Off-grid multifunction controller without storage Annexure I proposes an off-grid multifunction controller that can use solar power for pumping and other agricultural or household applications without a dedicated battery. The proposed configuration contains four outputs: A three-phase output dedicated to agricultural pumps or motors A three-phase variable-voltage and variable-frequency output for other agricultural equipment A single-phase variable-voltage and variable-frequency output for agricultural machinery A fixed-voltage, fixed-frequency single-phase output for household loads The annexure describes two three-phase outputs rated at 400 V and two single-phase outputs rated at 220 V, 50 Hz. Although the annexure refers to four independent outputs, the main body states that only one selected load should operate at a time. The controller interface must provide load selection and electrical and operational interlocking between the outputs. Off-grid multifunction controller with battery storage The draft permits a dedicated battery energy storage system to be integrated with the controller. The proposed battery bank would connect to the DC bus through a Dual Active Bridge converter. This arrangement allows electricity to flow in both directions between the battery and the controller. A storage-enabled system could: Continue supplying power during low solar irradiance Support loads outside sunshine hours Respond to temporary load variations Store surplus solar electricity Improve the reliability of irrigation and agricultural operations Support selected household or critical rural loads For functional verification, the solar PV array, controller, battery bank and DAB converter would be tested as an integrated system. For performance evaluation, the proposal requires separate assessment in solar-only, and battery-only modes. Hybrid controller with grid import and export The draft also describes a hybrid multifunction controller capable of interacting with the utility grid. Depending on the applicable regulatory framework, such a controller could: Export surplus solar electricity to the grid Import grid electricity when solar and battery power are insufficient Manage electricity among the PV system, battery, grid, agricultural loads and household loads Prioritise power sources for critical loads Operate through net-metering or behind-the-meter arrangements The proposal does not create an automatic right to export electricity. Grid export, net metering and interconnection would remain subject to applicable electricity regulations, distribution-company requirements, state rules and grid codes. Proposed Rating, Capacity and Marking Requirements The proposed requirements set clear expectations for the controller’s performance, identification, safety markings and operating conditions: 1. Controller rating The manufacturer would be required to declare the controller’s rated power. The proposed controller rating must be equal to or greater than the peak power of the connected PV array, as specified for the relevant water pumping system under MNRE specifications and IS 17018-1. The controller would also have to deliver its marked output power or rated current continuously for at least two hours while operating the pump at peak rated voltage and frequency. During this test, it should not: Trip an overcurrent-protection device Shut down due to over-temperature protection Fail to deliver the declared output 2. Rating plate and permanent markings The controller would require a permanent, weatherproof rating plate. The draft proposes: Minimum text height of 3 mm Minimum safety-symbol size of 10 mm Etched or embossed markings Markings that remain legible through the equipment’s service life The rating plate would include: Manufacturer’s name or trademark Model number Serial number Month and year of manufacture Maximum PV input voltage Maximum PV short-circuit current Maximum permissible PV array power MPPT voltage range Maximum current per MPPT input, where applicable Number of MPPT inputs, where applicable Motor output-voltage range Rated motor power Rated output current Supported motor type The draft further identifies the controller as: Overvoltage Category III Pollution Degree 3 IP65 or higher Equipment Class I Suitable for an ambient-temperature range of 0°C to 50°C Proposed safety markings include warnings relating to PV disconnection, protective earthing, hot surfaces and hazardous DC voltage. Wider PV Input-Voltage Operation The draft places considerable emphasis on wider input-voltage operation. This is intended to make controllers more adaptable to changes in PV module size, rating, voltage and efficiency. Manufacturers would declare minimum, nominal and maximum input-voltage values. Testing would then be conducted at: Minimum declared voltage Nominal voltage At least 90% of the maximum declared voltage For all motor-pump sets, the controller would have to operate at: Nominal voltage minus 15% Nominal voltage Nominal voltage plus 15% The controller would be expected to deliver rated power at each of these three voltage levels. The draft also proposes that the controller should continue operating where one PV module is added or removed, including variations associated with bypass-diode activation. Controllers rated at 10 kVA or above would require multi-channel MPPT to reduce array mismatch losses and improve energy harvesting. Proposed Efficiency Requirements Efficiency is where a solar controller proves its real value. The proposed requirements focus on reducing power losses, improving MPPT performance and making sure more of the available solar energy reaches the connected load. Power-conversion efficiency At or above 80% of rated PV power under standard test conditions, the draft proposes the following minimum conversion efficiency: Controller capacity Minimum conversion efficiency Below 5 kVA or 5 HP 93% 5 kVA or 5 HP and above 94% These limits would apply regardless of whether the controller uses a single-stage or two-stage design. Static MPPT efficiency Static MPPT efficiency measures how effectively a controller extracts available PV power under stable operating conditions. The draft proposes a minimum static MPPT efficiency of 98% across 10% to 100% of rated PV input power. Dynamic MPPT efficiency Dynamic MPPT efficiency measures performance while solar irradiance is changing. The draft proposes a minimum dynamic MPPT efficiency of 97% under hot-day and cold-day profiles specified under IS 17018-1. Overall system efficiency The proposed minimum overall efficiency at or above 80% of rated PV input power is: Controller Rating Conversion Efficiency MPPT Efficiency Minimum Overall Efficiency Below 5 HP At least 93% At least 97% At least 90.2% 5 HP and above At least 94% At least 97% At least 91.2% Testing would be carried out at minimum, nominal and 90% of maximum DC input voltage, with measurements at 10%, 25%, 50%, 75% and 100% input-power levels. Motor Control and Agricultural Load Operation The draft allows controllers to use constant V/f control, flux control or an equivalent manufacturer-developed control algorithm. The controller should provide stable operation from zero speed to rated speed. For a universal or multifunction solar pump controller used with equipment such as flour mills and chaff cutters, the draft proposes a minimum torque-overload capability of 150% for 30 seconds. The overload test may be conducted by: Increasing mechanical torque to 150% of rated torque; or Increasing motor current to 150% of rated current Annexure II also allows laboratories to use simulated loads instead of procuring every type of farm equipment. Dynamometers, motor arrangements, resistive loads and programmable load banks may be used to recreate relevant operating conditions. If the applied torque exceeds the permissible limit, the controller should initiate protective action and generate a torque-overload alarm or fault indication. Power-Quality Requirements Poor power quality can quietly damage motors, increase heating and shorten equipment life. The proposed requirements aim to keep the controller’s output within safe limits and maintain reliable motor performance under different operating conditions. 1. Sinusoidal motor output For induction and PMSM motors operating with a sinusoidal output the proposed limits are: Total harmonic distortion not exceeding 10% No individual harmonic exceeding 6% of the fundamental component Testing at 25% or minimum continuous load, 50% load and 100% rated load Harmonic evaluation from the second to the fortieth order These requirements are intended to reduce motor heating, insulation stress, torque ripple and long-term performance problems. 2. Intentionally non-sinusoidal output For controllers designed to supply a non-sinusoidal waveform to dedicated motor loads, the draft proposes: Voltage THD not exceeding 40% Voltage-transition slope not exceeding 10 V/µs Peak output voltage not exceeding 1.414 multiplied by 110% of rated RMS voltage. Verification at 10%, 50% and 100% of rated output power. Evidence that the controller-motor combination can operate without excessive heating, insulation stress or protection failure. 3. Voltage spikes For a 415 V motor system with more than 60 metres of cable, the proposed peak voltage at the motor terminals must not exceed 620 V. The spike duration must remain below 1 microsecond. Electrical Safety Requirements The draft also lays down safety checks for high-voltage electrical parts. These cover insulation, leakage current and stored charge, to reduce the risk of electric shock during use or maintenance. 1. Insulation withstand The draft proposes humidity preconditioning before dielectric testing. The controller would be exposed to 92% relative humidity at 40°C for 48 hours. The proposed dielectric test voltage is calculated as: Two times the maximum PV input voltage plus 1,000 V AC The voltage would be applied at 50 Hz for one minute. The proposed acceptance criteria are: Leakage current not exceeding 5 mA RMS No insulation breakdown No flashover No arcing Insulation resistance greater than 100 MΩ at 500 V DC after the test 2. Touch-current Limits During rated operation, the proposed limits are: Maximum 3.5 mA AC leakage Maximum 10 mA DC leakage 3. Stored-energy Discharge After disconnecting the PV input, the voltage at the PV terminals must fall below 60 V within 10 seconds. This requirement is intended to reduce the risk of electric shock during servicing or maintenance. Environmental-Protection Requirements Solar pump controllers are commonly installed in dusty fields and exposed to humidity, rain and high temperatures. The draft therefore classifies the equipment for Pollution Degree 3 and Overvoltage Category III conditions. 1. IP65 enclosure test The draft proposes both dust and water-jet testing. For dust protection, the controller would be exposed to circulating talcum powder at 2 kg/m³ for approximately eight hours, with a negative internal pressure of 2 kPa. For water protection, jets would be directed from multiple angles at a distance of 2.5 to 3 metres. The equipment would then be drained before inspection. The controller would pass where: No visible dust enters the enclosure No water accumulates in a manner affecting components or operation Normal operation continues after testing 2. Humidity Exposure The proposed humidity preconditioning is: 92% relative humidity, with a tolerance of ±3% 40°C, with a tolerance of ±2°C Continuous exposure for 48 hours No internal drying before dielectric testing Dielectric testing within two hours after removal 3. Impulse-voltage withstand The proposed impulse test uses a 6 kV peak impulse: Three positive pulses Three negative pulses Minimum one-minute interval Application between PV and motor, PV and earth, and motor and earth The controller would have to show no flashover, puncture, excessive leakage or component disruption. Thermal and Fault-Condition Tests The proposed tests focus on safe operation during heat, faults and abnormal conditions, with added safeguards for battery-based systems. Normal Thermal Test The controller would operate for four hours under rated conditions. Proposed maximum temperatures include: Component Maximum temperature Touchable metal surface 65°C Touchable metal surface 75°C Operator controls 55°C Transformer or motor windings 155°C for Class F Semiconductors Manufacturer’s datasheet limit Fan-block Test The draft proposes blocking controller vents or heat sinks with surgical cotton and operating the controller at full load for seven hours. The proposed acceptance conditions are: External surface temperature not exceeding 90°C No ignition No evidence of scorching or burning Output short-circuit Test Motor terminals would be shorted under full PV input. The test would record current, clearing time and controller response. The controller would need to remain stable or activate protection without causing fire or enclosure deformation. Dry-run Protection The controller should detect pump operation without adequate water and display a dry-run error. Open-circuit and reverse-polarity protection The controller should detect an open PV circuit and reverse polarity and provide a corresponding fault indication. Battery Storage and Charging Requirements Where a controller contains a battery-charging function, the draft proposes additional compliance with IS 16797:2019 and IEC 62509:2010. The proposed battery provisions include: Settable charging logic Constant-current and constant-voltage charging for LFP batteries Boost and float charging for lead-acid batteries Overcharge protection Over-discharge protection Load disconnection Charging set-point accuracy of ±1% Load-disconnect accuracy of ±2% Protection against unauthorised set-point changes Temperature-compensated charging, where applicable Reverse-polarity protection PV-side and load-side overcurrent protection Charging-status indication State-of-charge information Low-battery and load-disconnect alarms Annexure II contains blank spaces for manufacturer-specific charging currents, voltage cut-offs and set points. These values would need to be declared and verified for the particular battery system. Grid-Feeding and Anti-Islanding Requirements For grid-connected operation, the proposed hybrid controller would have to meet the anti-islanding requirements of IEC 62116 and the applicable safety provisions of IS 16221 Part 2. If the utility grid fails, the controller would have to: Detect the abnormal condition Disconnect from the grid within two seconds Prevent unintentional islanding Protect utility personnel and connected equipment Before connecting or reconnecting, the controller would need to synchronise its voltage, frequency and phase angle with the grid in accordance with IEC 61727 and the applicable Indian grid code. These technical provisions do not replace state-level interconnection, net-metering or distribution-licensee requirements. Remote Monitoring, Display and Alarm Requirements The draft proposes integration with a remote monitoring system using GSM or GPRS and geotagging. The controller display and remote system would provide information such as: Pump on/off status Fault name Dry-run fault Short-circuit fault Low-irradiance condition PV array input voltage DC and AC current DC and AC output voltage Operating frequency Latitude and longitude Pump capacity PV module capacity Current power generation Daily solar generation Cumulative solar generation Daily operating hours Cumulative pump operating hours Daily or cumulative water discharge Peak power supplied to the motor-pump set The draft does not expressly prescribe data-retention periods, cybersecurity controls, data ownership, communication charges, portal integration or privacy safeguards for this proposed controller-specific framework. These areas may require clarification before final implementation. Proposed Type-Test Sequence The draft includes a sequential testing structure covering: Visual inspection and rating-plate verification Humidity exposure Dielectric withstand Impulse-voltage withstand Touch-current measurement Stored-energy discharge Normal thermal testing IP65 testing Output-waveform testing Short-circuit testing Backfeed testing Fan-block testing Overload testing Efficiency testing Power-quality testing The table itself skips sequence number 14 and labels the last tests as 15 and 16. This appears to be a numbering issue rather than evidence of an omitted technical requirement, but it should be clarified in the final version. The draft also proposes a post-test protocol after every test. This includes dielectric verification, insulation-resistance measurement, visual inspection and confirmation that the controller can still perform its basic PV-to-motor function. Annexure II: Multifunction Controller Testing Annexure II provides a testing format for an off-grid multifunction controller. The laboratory would verify: Application selection through the controller display Automatic mode selection through a keypad or remote interface Prevention of manual changeover Application-specific software Operation across the declared PV input-voltage range Efficiency under hot and cold irradiance profiles Solar-only and battery-only performance Output ripple and distortion Three-phase and single-phase waveforms Operation at lower PV power levels Torque performance Battery charging Load disconnection Overcurrent protection Reverse-polarity protection Alarm functions Safety markings Touch current Impulse withstand Thermal limits Total circuit protection Actual flour mills, chaff cutters, freezers and farm equipment would not necessarily need to be installed in the laboratory. Equivalent loading could be simulated through motors, dynamometers, programmable loads and load banks. Likely Business Impact The proposed changes could affect manufacturers, testing bodies, system integrators and end users across the solar and rural-energy ecosystem. 1. Solar Pump Controller Manufacturers Manufacturers may need to review their hardware, firmware, enclosure, rating plate and thermal design against the proposed requirements. The wider voltage range, efficiency limits, IP65 tests, impulse withstand, multifunction outputs and detailed type-test sequence could require design changes or additional evidence. 2. PM-KUSUM Vendors and System Integrators Vendors may need to ensure that controller ratings match the connected PV array rather than only the pump’s motor rating. They may also need to verify compatibility among: PV modules Controllers Motor-pump sets Battery systems DAB converters Remote monitoring systems Grid interfaces 3. Testing Laboratories Testing laboratories could see increased demand for combined electrical, environmental, performance and functional testing. However, laboratories may require additional equipment for: Dynamic MPPT testing Hot and cold irradiance profiles Torque simulation IP65 testing Humidity preconditioning Impulse testing Battery-system assessment Grid-interactive and anti-islanding testing 4. Battery and Power-electronics Businesses The proposed storage configuration may create opportunities for battery manufacturers, DAB converter developers, energy-management providers and rural-energy solution companies. These opportunities remain dependent on the final specification, scheme design and procurement framework. 5. Farmers and Rural Users If implemented effectively, multifunction controllers could help farmers use solar electricity for more than irrigation. Potential applications include: Flour milling Chaff cutting Farm machinery Cold storage Refrigeration Household loads Community-energy applications The practical benefit would depend on system cost, available PV capacity, load compatibility, safe wiring, maintenance support and operating rules. Drafting Issues That May Require Clarification Stakeholders should consider raising the following points during consultation: 1. Different dates on the Memorandum and MNRE Webpage The office memorandum asks for comments by 28 August 2026. The MNRE notice webpage displays an end date of 11 October 2026. The Ministry may need to clarify the controlling consultation deadline. 2. Output-voltage Differences Annexure I refers to 220 V single-phase output, while Annexure II refers to 230 V single-phase output. The document also refers to 400 V, 415 V and up to 440 V in different contexts. These values may describe different operating or test conditions, but the final specification should explain their relationship clearly. 3. Different Distortion Limits The main body permits up to 10% THD for sinusoidal output and up to 40% for intentionally non-sinusoidal motor output. Annexure II separately states that ripple and distortion should be below 5% after 25% loading. The final document should explain whether the 5% requirement applies to voltage ripple, waveform distortion, a particular output or a separate measurement. 4. Insulation-resistance Inconsistency Clause 8.1 requires insulation resistance greater than 100 MΩ at 500 V DC after dielectric testing. The post-test protocol later refers to a value greater than 50 MΩ. A single acceptance limit should be specified. 5. Section and Test Numbering The draft contains repeated or missing numbering, including: Two different sections numbered 10 A type-test sequence that skips number 14 Annexure II skipping item 8 Duplicate overcurrent-protection entries numbered 18 and 19 A later display and monitoring section also numbered 13 Renumbering would improve usability and prevent test-reporting errors. 6. Cross-reference Issues The humidity section refers to dielectric testing under clause 6.1, although the relevant insulation test appears under clause 8.1. Cross-references should be checked before finalisation. 7. Four Outputs versus One Operating Load Annexure I describes four independent outputs, while the main body states that only one load may operate at a time. The final specification should clarify whether “independent” refers only to separate terminals and software configurations. 8. Testing and Certification Mechanism The draft requires independent testing but does not expressly specify: Which laboratories may conduct the tests Whether NABL accreditation is required Applicable accreditation scopes Whether one sample or multiple samples must be tested Test-report validity Retesting after design changes Surveillance requirements Product certification or registration procedure 9. Treatment of Existing Controllers The draft does not explain how a final specification would affect: Controllers already installed Products already type-tested Existing PM-KUSUM contracts Current tenders Products in inventory Models undergoing testing A transition or grandfathering framework may therefore be necessary. 10. Data and Remote-monitoring Governance The proposal lists extensive operational and geolocation data but does not expressly address cybersecurity, data ownership, access rights, retention, communication failure or portal interoperability. 11. Grid-interconnection Dependencies The hybrid model refers to grid import, export, net metering and behind-the-meter operation. The final document should clearly distinguish controller capability from the separate regulatory permission required for grid connection and export. How to Submit Comments The office memorandum invites comments from stakeholders by 28 August 2026. Comments may be sent to: rajkumarb.mnre@gov.in kamlesh.yadav@nise.res.in The memorandum does not prescribe a specific comment format. A structured clause-wise submission would make stakeholder feedback easier to evaluate. A useful comment matrix may contain: Draft clause- Existing wording- Issue identified- Suggested wording- Technical justification Stakeholders should support comments with test data, applicable standards, field-performance evidence, safety analysis or cost implications wherever possible. What Businesses Should Do Next 1. Conduct an Applicability Review Determine which controller models, motor technologies, operating modes and product configurations fall within the proposed scope. 2. Compare Existing Products with the Draft Prepare a technical gap assessment covering: Input-voltage range MPPT capability Efficiency Power quality Enclosure protection Electrical safety Thermal performance Fault protection Marking Remote monitoring Battery compatibility Grid-interactive functions 3. Review Available Test Evidence Identify which proposed requirements are already covered by current test reports and which would require fresh testing. 4. Assess Laboratory Capability Consult testing laboratories about equipment, accreditation scope, sample requirements, test duration and likely capacity constraints. 5. Identify Unclear or Conflicting Provisions Document any technical ambiguity that could affect design, testing, cost, procurement or interoperability. 6. Submit Evidence-based Comments Send clause-wise comments before the deadline stated in the office memorandum. Avoid limiting the submission to broad commercial objections. 7. Avoid Premature Compliance Claims Do not market a product as compliant with a final MNRE 2026 specification until the draft is finalised and the applicable conformity route is established. 8. Monitor the final Version Track MNRE notices for a final specification, revised draft, implementation timeline, transition arrangements or scheme-level adoption. How Corpseed Can Help Businesses involved in solar pumping and rural-energy systems may require both regulatory interpretation and technical coordination to respond effectively to the draft. Corpseed can assist with: Applicability assessment for controller models Clause-wise review of the proposed specification Technical compliance gap assessment Preparation of structured stakeholder comments Review of rating plates and technical documentation Coordination with suitable testing laboratories Review of existing test reports against proposed requirements Battery-storage and multifunction configuration assessment Grid-interactive requirement mapping PM-KUSUM tender and specification review Ongoing monitoring of the final MNRE requirements The purpose of this support is to help manufacturers and vendors understand the proposal, identify genuine technical gaps and prepare an evidence-based response. Final acceptance, testing, certification or approval would remain subject to the competent authority and applicable laboratory or scheme procedures. Businesses that manufacture, supply, test or integrate solar pump controllers can seek specialised solar pump technical compliance consulting before submitting comments or planning product changes.

Subject

Summary: The Micro, Small and Medium Enterprises Development (Amendment) Act, 2026 received the Presidential assent and was notified on 13 August 2026 as Act No. 16 of 2026. This Act is an amendment to the Micro, Small and Medium Enterprises Development Act, 2006, commonly known as the MSMED Act. This act of 2026 amends the enterprise's classification and registration procedures. Moreover, it makes it mandatory to route certain public sector invoice payments through the Trade Receivables Discounting System (TReDS). The time limit for payment disputes has been reduced under this Act. It also improves the settlement process and the enforcement of awards. The Act becomes law, but its provisions do not automatically become operative on 13 August 2026. According to Section 1(2), the Central Government will notify the date of coming into force of the Act in the Official Gazette. Provisions of the Act may come into force on different dates. However, no separate notification of commencement was found after reviewing an official source on 14 August 2026. Notification at a Glance Particular Verified details Issuing authority Ministry of Law and Justice, Legislative Department Document type Act of Parliament Title Micro, Small and Medium Enterprises Development (Amendment) Act, 2026 Act number No. 16 of 2026 Date of assent and publication 13 August 2026 Effective date To be appointed by the Central Government through Official Gazette notification, different dates may be appointed for different provisions Principal law amended Micro, Small and Medium Enterprises Development Act, 2006 (Act No. 27 of 2006) Main subjects MSME classification, registration, TReDS settlement, dispute resolution, award enforcement, MSEFC structure, reporting, penalties and appeals Main stakeholders MSMEs, Central Public Sector Enterprises, notified buyers and authorities, State Public Sector Enterprises, MSEFCs, courts, mediation providers and compliance teams Compliance deadline Not expressly specified in the Act, commencement and operational rules are pending Nature of requirement A mix of statutory amendments, enabling powers and duties requiring commencement, rules or notifications The date of assent is not the same as the date of effect. The significance of this differentiation will determine when companies should alter their operations. Legal Status, Assent and Commencement The document is legislation, not a Bill or an advisory one. It is noted in the Gazette that the President gave his assent to it on 13 August 2026. Thus, its legal status differs from that of the MSME Development (Amendment) Bill, 2026, which was debated in Parliament. However, section 1(2) uses a notification-based commencement model. The Central Government may commence the whole Act on one date or appoint different dates for different provisions. A provision does not become operational only because the Act was passed, assented to, or published. This creates three separate checks for every affected business: Has the relevant section been brought into force? Has the required rule, form, procedure, platform, or entity notification been issued? Does an existing notification continue under the saving clause, or has it been replaced? Until these questions are answered for a provision, implementation teams should treat the Act as an enacted framework awaiting operational activation, not as a complete set of immediately enforceable procedures. The Regulatory Framework The Micro, Small and Medium Enterprises Development Act, 2006 is the main law governing the recognition, promotion and development of MSMEs in India. Among other matters, it deals with enterprise classification, government support measures, access to credit, public procurement, and protection against delayed payments. The 2026 amendment does not introduce an entirely new law. Instead, it revises selected provisions of the existing MSMED Act and adds several new sections. It also gives the Central and State Governments powers to prescribe detailed procedures. This means the amendment cannot be read in isolation. Businesses must also check the principal Act, commencement notifications, implementing rules, and prescribed forms. Some provisions also work alongside other legal and regulatory systems: Mediation Act, 2023: Amended section 18 applies this law to mediation in MSME payment disputes, subject to the special 90-day period introduced by the amendment. Insolvency and Bankruptcy Code, 2016: New section 18A states that an amount determined through a mediated settlement agreement or arbitral award will be treated as a valid and legally enforceable debt. Its use in an insolvency proceeding will still depend on the applicable provisions of the Code. Reserve Bank of India’s TReDS framework: New section 15A requires specified entities to route the settlement of MSME invoices through a Trade Receivables Discounting System platform authorized by the Reserve Bank of India. The operation of these platforms is separately governed by the Reserve Bank of India (Trade Receivables Discounting System) Directions, 2026. These connected laws perform different functions. The MSMED Act creates the relevant rights and obligations, while the other frameworks govern mediation, insolvency recognition, and the operation of TReDS platforms. What Has Changed The amendment covers much more than MSME registration. Its main changes are: A new statutory definition of the Development Commissioner. A revised, notification-based framework for classifying micro, small, and medium enterprises using both investment and turnover. Free and voluntary memorandum filing through a national digital platform, with an enabling power for State platforms. Mandatory routing of specified public-sector invoice settlements through an RBI-authorised TReDS platform. Statutory periods for mediation, arbitration referral, and making awards. Online mediation and arbitration through a future Central Government mechanism. Recovery of mediated settlements and arbitral awards as arrears of land revenue. Recognition of determined amounts as legally enforceable debt under the Insolvency and Bankruptcy Code, 2016. Revised pre-deposit and supplier-payment protections when an award or settlement is challenged. More Micro and Small Enterprises Facilitation Councils (MSEFCs), revised composition, and regular meetings. TReDS invoice reporting by covered public-sector and notified entities. A warning-and-penalty framework, adjudication by the Development Commissioner, and an administrative appeal. Compliance area Earlier position New position under the amendment Business meaning MSME classification Section 7 contained category wording and statutory investment limits, subject to existing powers Central Government may notify classification limits using both investment and turnover Classification will depend on future notification under the amended provision Registration memorandum Different statutory treatment applied across enterprise categories Free and voluntary filing for MSMEs through notified national or State digital platforms Registration is framed as voluntary, but it remains relevant for benefits and supplier jurisdiction TReDS No equivalent section 15A in the principal Act CPSE invoice settlement must be routed through an RBI-authorised TReDS platform other entities may be notified Covered buyers may need procurement, ERP, treasury, and payment-system changes Mediation Section 18 applied mediation provisions Mediation must finish within 90 days from the date fixed for first appearance MSEFCs and parties receive a specific statutory time limit Arbitration No equivalent amended deadlines Referral within 30 days after mediation ends, award within 90 days after pleadings finish Dispute management should become more time-bound Enforcement Enforcement depended on existing legal mechanisms Award or mediated settlement may be recovered as arrears of land revenue and recognized as enforceable debt under the IBC Successful suppliers receive additional recovery routes, subject to process Penalties Existing offense and court-based framework Graduated warnings, penalties or fines, administrative adjudication and appeal Covered persons need stronger information and reporting controls Complete Section-Wise Amendment Map Amendment section Principal provision affected Main change 2 Section 2 Defines Development Commissioner and updates cross-references in MSME definitions 3 Section 3(3)(o) Makes the Development Commissioner the relevant member of the National Board 4 Section 7(1) Replaces the enterprise-classification provision 5 Section 8 Replaces memorandum filing with free and voluntary digital registration 6 Section 14(2) Removes the reference limited to section 9(1) 7 New section 15A Introduces mandatory TReDS invoice settlement for specified buyers 8 Section 18 Adds mediation and arbitration timelines, jurisdiction, and online proceedings 9 New section 18A Adds recovery and debt-recognition provisions 10 Section 19 Replaces rules for challenging awards, orders, and mediated settlements 11 Section 20 Requires an adequate number of MSEFCs and regular meetings 12 Section 21 Revises MSEFC membership and composition 13 New section 22A Creates TReDS invoice disclosure obligations 14 Sections 27 and 27A Revises consequences, adjudication, and appeals 15 Section 29 Expands Central Government rule-making subjects 16 Section 30 Expands State Government rule-making subjects 17 Saving clause Continues consistent existing actions and notifications until revoked Revised MSME Classification Framework Amended section 7(1) authorizes the Central Government to classify enterprises as micro, small, or medium by notification. The Government must use both of these criteria: Investment in plant, machinery, or equipment. Turnover. The amendment itself does not state the rupee limits for the three categories. Those limits must be specified through a notification. Businesses should therefore not infer fresh thresholds from the Act. The provision continues to exclude the cost of pollution-control equipment, research and development, industrial-safety devices, and other notified items from the calculation of investment in plant and machinery. It also states that section 29B of the Industries (Development and Regulation) Act, 1951, will apply to the enterprises specified in the amended section 7(1). The commercial effect is greater flexibility for the Central Government to revise classifications by notification without amending the rupee thresholds in the Act itself. Existing and proposed enterprises should monitor the first notification issued under the amended section and check whether it changes their category or eligibility for benefits. Free and Voluntary MSME Registration Substituted section 8 provides for a national digital platform for the free and voluntary filing of a memorandum for MSME registration. The purpose stated in the Act is to enable registered enterprises to obtain benefits from the Central Government under the MSMED Act. A State Government may notify a State digital platform for free and voluntary memorandum filing to obtain applicable State benefits. A State may also extend State scheme benefits to MSMEs registered on the national platform. The Central and State Governments must prescribe the form and manner of filing. The amendment does not itself name the future national platform or provide a filing workflow. Businesses should not assume that every existing portal feature, data field, or verification step will remain unchanged after commencement. Voluntary filing does not mean registration has no legal value. The amended dispute provision links MSEFC jurisdiction to the supplier's official address in its section 8 registration. Registration may also be required to access certain government benefits. Businesses should assess the legal and commercial value of filing even though the amended provision describes it as voluntary. Mandatory Invoice Settlement Through TReDS New section 15A requires every Central Public Sector Enterprise (CPSE) to route settlement of invoices for goods or services procured from MSMEs through an RBI-authorised TReDS platform. The Central Government must prescribe the form and manner. The Central Government may notify another authority, body, or entity that must follow the same settlement route. A State Government may separately notify a State Public Sector Enterprise or another authority, body, or entity. These enabling powers do not make every private buyer, State enterprise, or government-controlled body immediately subject to section 15A. TReDS is an electronic platform used to facilitate financing or discounting of MSME trade receivables. Under RBI's 2026 Directions, the platform can support uploading, acceptance, bidding, discounting, and settlement of invoices, including financed and unfinanced transactions. The statutory requirement to route settlement through TReDS should not be described as a guarantee that every invoice will be discounted or financed. Likely operational effect on covered buyers Subject to commencement and prescribed procedures, covered entities may need to: Map MSME vendors accurately in procurement and finance systems. Connect purchase orders, invoice acceptance, and payment approvals with TReDS workflows. Define responsibility for invoice uploading, acceptance, dispute flags, and settlement. Reconcile TReDS records with enterprise resource planning and bank payment records. Preserve evidence of invoices routed and settled through the platform. Prepare for the disclosure obligation under the new section 22A. These are practical readiness measures. The exact statutory workflow will depend on the rules made under sections 15A, 29, and 30. Reporting of TReDS Invoice Compliance New section 22A creates a disclosure duty for entities covered by section 15A. Central Public Sector Enterprises and other Central Government-notified bodies must disclose details of MSME invoices routed and settled through TReDS in the form and manner prescribed by the Central Government. State Public Sector Enterprises and other State-notified bodies face a corresponding State-prescribed disclosure requirement. The Act does not specify the reporting frequency, data fields, recipient, filing portal, or retention period. This provision will require consistency between procurement data, TReDS activity, and statutory reporting. Covered entities should plan a control that can trace each reported invoice from purchase and acceptance through routing and settlement. MSME Delayed-Payment Dispute Resolution The amendment adds fixed periods to section 18 of the principal Act and expands the permitted use of electronic proceedings. Stage Starting point Statutory period Responsible body Mediation Date fixed for first appearance 90 days MSEFC or mediation service provider Referral after failed mediation Date mediation terminates 30 days MSEFC Arbitral award Date pleadings are completed 90 days MSEFC or ADR institution/centre Appeal against penalty order Receipt of adjudicating officer's order 30 days, subject to condonation for sufficient cause Aggrieved person Disposal of penalty appeal Date appeal is filed 60 days Appellate authority The 90-day mediation period replaces the completion period that would otherwise apply under section 18 of the Mediation Act, 2023, for these proceedings. The arbitration deadline runs from completion of pleadings, not from the original reference or first appearance. Amended section 18(5) gives jurisdiction to the relevant MSEFC, mediation provider, or alternative dispute resolution institution where the supplier's official address under section 8 registration is located, even when the buyer is elsewhere in India. The Central Government may establish an online mechanism for mediation or arbitration through audio-video and other electronic means. The Act recognizes video conferencing, electronic filing of pleadings, communication, recording of evidence, and transmission of electronic communications. The actual procedure must be prescribed later. Enforcement of Settlements and Awards New section 18A adds two enforcement consequences for a mediated settlement agreement or arbitral award made by an MSEFC or a referred mediation or arbitration provider. First, the State Government may recover the amount as arrears of land revenue through the District Collector, Deputy Commissioner, or another State-notified authority where the buyer's assets are located. Second, the amount determined by the settlement or award constitutes a valid and legally enforceable debt and is liable to be recognized under the Insolvency and Bankruptcy Code, 2016. These provisions strengthen the legal character of the determined amount. They do not guarantee immediate collection or prove that insolvency proceedings will succeed. Recovery will remain subject to the applicable statutory process, jurisdiction, available assets, and any valid challenge. Challenging an Award or Mediated Settlement Substituted section 19 applies to an application seeking to set aside a decree, award, other order, or mediated settlement agreement made under section 18. An applicant who is not the supplier must deposit 75% of the amount stated in the award or mediated settlement agreement before a court may entertain the application. While the challenge is pending, the court must direct payment to the supplier of a percentage of the deposited amount that it considers reasonable. If the application has remained pending for more than six months, the court must order payment to the supplier of at least 50% of the awarded amount from the deposit. The application must be filed in the court having jurisdiction over the supplier's official address, as per Section 8. Buyers considering a challenge should account for the deposit requirement and the risk of supplier release before initiating litigation. Suppliers should keep their registered official address accurate because it affects jurisdiction under sections 18 and 19. Expansion and Composition of MSEFCs Substituted section 20 requires each State Government to establish an adequate number of MSEFCs in addition to its existing Council. The State notification will specify its location, territorial jurisdiction, and the areas it covers. Councils must meet regularly to ensure the timely disposal of section 18 references. The State Government will prescribe the meeting interval and procedure. A State may also provide physical infrastructure, digital systems, and trained personnel. Under substituted section 21, each Council must have at least three and no more than five members. It must include: An officer not below the rank of Joint Director as Chairperson. One or more office-bearers or representatives of micro or small industry or enterprise associations. At least one member from the field of law. The State Government will prescribe the detailed composition, the filling of vacancies, and the procedure for members. The express requirement for legal representation may support more consistent handling of mediation, arbitration, and enforcement issues, although the practical result will depend on appointments and State capacity. Penalties Under the Amended Act The substituted section 27 creates graduated consequences for specified contraventions. Contravention First instance Later instance Wilfully furnishing false information in the section 8 registration memorandum Warning Penalty of at least Rs. 1,000 and up to Rs. 50,000 for the second or any subsequent instance Failure to comply with section 26(2) Warning Penalty of at least Rs. 1,000 and up to Rs. 50,000 for the second or any subsequent instance Buyer contravening section 22 annual-account disclosure Warning Second contravention: penalty of at least Rs. 10,000 and up to Rs. 50,000, third or subsequent contravention: fine of at least Rs. 50,000 and up to Rs. 1 lakh Section 27(3) states that penalties under the section will increase by 10% of the prescribed minimum amount after every three years from the commencement of the amendment, as notified by the Central Government. The future notification should be checked before calculating an escalated minimum. Section 22 concerns the disclosure of unpaid amounts and interest due to micro or small suppliers in the buyer's annual statement of accounts. New section 22A, dealing with TReDS reporting, is separate and is not expressly listed in the penalty table under amended section 27. Adjudication and Appeal New section 27A changes how penalties under section 27 are imposed. The Central Government must appoint the Development Commissioner as the adjudicating officer. The officer will conduct an inquiry and impose a penalty in the manner prescribed by the Central Government. No penalty may be imposed without giving the affected person a reasonable opportunity to be heard. An aggrieved person may appeal to the Secretary to the Government of India who is in charge of the Ministry or Department administering MSMEs. The normal period is 30 days from receipt of the adjudicating officer's order. A delayed appeal may be admitted if sufficient cause is shown. The appellate authority must give the party an opportunity to be heard and is expected to dispose of the appeal within 60 days of filing. An unpaid penalty confirmed by the adjudicating officer or appellate authority may be recovered as arrears of land revenue. Central and State Government Responsibilities Function Central Government State Government MSME classification Notifies classification limits No equivalent power stated in amended section 7(1) Registration Notifies classification limits May notify State platform and prescribe State filing form/manner TReDS settlement Prescribes CPSE and Central-notified entity process May notify covered State entities and prescribe their process Online dispute resolution May establish mechanism and prescribe procedure No equivalent mechanism stated in amended section 18 MSEFC structure No direct establishment role in substituted section 20 Establishes Councils and prescribes meetings, composition and procedure TReDS disclosure Prescribes reporting for CPSEs and Central-notified entities Prescribes reporting for State-notified entities Penalty adjudication Appoints Development Commissioner and prescribes inquiry/appeal procedure No equivalent adjudication role under section 27A Businesses operating in more than one State may therefore face a common Central framework alongside different State notifications and Council procedures. Provisions Requiring Further Rules or Notifications The amendment leaves several operational matters to delegated legislation. Provision Pending action Responsible authority Section 1(2) Commencement date or dates Central Government Section 7(1) MSME classification limits Central Government Section 8(1) National digital platform and filing procedure Central Government Section 8(2) State platform and filing procedure State Government Section 15A Form and manner of TReDS settlement, possible notification of more entities Central or State Government Section 18(6)-(7) Establishment and procedure of online dispute mechanism Central Government Section 20 MSEFC meeting interval and procedure State Government Section 21 Council composition details, vacancies, and member procedure State Government Section 22A TReDS invoice disclosure form and manner Central or State Government Section 27(3) Three-year penalty increase notification Central Government Section 27A Inquiry, penalty, and appeal procedure Central Government The Act sets the legal direction, but these instruments will determine how covered entities perform many of the new duties. Saving of Existing Actions and Notifications Section 17 of the amendment preserves anything done, action taken, or notification issued under the principal Act, but only to the extent that it is consistent with the amended Act. Such action continues until revoked and is treated as if taken under the corresponding amended provision. This clause may reduce disruption to existing registrations, notifications, and administrative actions. It does not mean that every earlier instrument survives despite inconsistencies. Businesses should compare an existing notification with the amended provision and check whether the Government has revoked, replaced, or clarified it. Scope and Applicability Stakeholder Covered? Relevant condition Main concern Micro, small and medium enterprises Yes Classification and voluntary registration provisions Category, registration data, and access to benefits Micro and small suppliers Yes Delayed-payment protections apply to statutory suppliers Registered address, evidence and dispute timelines CPSEs procuring from MSMEs Expressly covered by section 15A From relevant commencement and prescribed procedure TReDS routing and reporting Other Central authorities, bodies or entities Conditionally Only if notified by the Central Government Notification monitoring State PSEs and other State bodies Conditionally Only if notified by the State Government State-specific implementation Private buyers Not automatically covered by section 15A May remain subject to other MSMED Act duties, section 15A applies only if lawfully notified Payment and section 22 disclosure controls MSEFCs and ADR providers Yes Amended section 18 and State implementation Case timelines, jurisdiction and digital procedure Impact on Businesses MSMEs and Suppliers MSMEs may benefit from digital registration, defined dispute timelines, and stronger recovery provisions. Suppliers should maintain accurate registration details and complete records of orders, deliveries, invoices, acceptance, and payments. CPSEs and Notified Buyers Covered buyers may need to route MSME invoice settlements through TReDS and report the relevant details. This could require changes across procurement, finance, treasury, and accounting systems. Finance and Compliance Teams Teams must keep invoice and vendor data accurate. They should also separate existing section 22 disclosures on unpaid dues from the new TReDS reporting requirement under section 22A. State Governments and MSEFCs States may need additional MSEFCs, trained staff, and better case-management systems. These resources will be important for meeting the new mediation and arbitration timelines. Benefits and Implementation Challenges Likely benefits include: A more flexible classification framework based on investment and turnover. Free and voluntary registration through digital platforms. Better payment traceability for covered public-sector procurement. Faster statutory stages for mediation and arbitration. Stronger routes for enforcing settlements and awards. Legal expertise within each MSEFC's required composition. A hearing and appeal framework for administrative penalties. Likely implementation challenges include: Coordinating commencement dates with multiple supporting rules. Integrating TReDS with procurement, acceptance, ERP, and banking systems. Maintaining reliable MSME vendor classification and registration data. Reconciling invoice-level reporting across platforms. Building MSEFC capacity to meet the new periods. Tracking different State notifications and procedures. These are business implications, not additional legal duties created outside the Act. Risks and Consequences of Non-Compliance Once the relevant provisions come into force, source-based consequences may include warnings, monetary penalties, a fine for repeated contraventions of section 22, and recovery of unpaid penalties as arrears of land revenue. Practical risks may include: Payment delays caused by incomplete TReDS integration. Inconsistent invoice data across procurement and finance systems. Weak defense in a payment dispute because acceptance or communication records are missing. Filing in the wrong forum because the supplier registration details are outdated. Incorrect public reporting of unpaid or TReDS-settled invoices. Budget pressure from the 75% deposit required for a challenge. Organizations must not assume that all consequences will apply from the date of consent. The commencement and implementation of the instrument remain key. What Businesses Should Do Next Monitor commencement notices. Capture the start date for each provision rather than relying on 13 August 2026 as a general effective date. Create a delegated legislation register. Monitor classification limits, registration forms, TReDS procedures, reporting formats, online dispute rules, and adjudication rules. Review vendor master data. Identify MSME suppliers and verify registration number, category, and official address. Workflow map of the invoice process. CPSEs and potentially notified entities must provide documentation of their invoice process from procurement through TReDS to final payment. Test reporting control processes. Verify that the annual accounting reports per section 22 and future TReDS reporting under section 22A may be reconciled to source documents. Enhance the dispute file. Save contracts, purchase orders, proof of delivery, any objection in writing, proofs of acceptance, invoices, and payment correspondence. Litigation Funding. Buyers need to have the 75% statutory deposit in place before challenging a decision or settlement. State Action. State PSEs, suppliers, and multi-state entities must monitor State notifications, jurisdiction of MSEFC, and procedures. Regulatory Developments to Monitor Businesses should watch for: A notification commencing all or selected provisions. New MSME classification limits under Section 7. Notification of the national registration platform. State digital-platform notifications. Central and State TREDS settlement rules. Notifications extending Section 15A to more entities. TReDS disclosure formats under Section 22A. Online mediation and arbitration rules. State rules for MSEFC meetings and composition. Central rules for penalty inquiries and appeals. How Can Corpseed Help? The 2026 amendment may require businesses to revisit multiple areas of compliance. A company may need to check its MSME records, confirm the status of its vendors, change how invoices are processed, and keep closer track of payment disputes. The work involved will depend on which provisions are brought into force and what the Central or State Government subsequently prescribes. Corpseed can help affected businesses identify relevant requirements and organize supporting registrations, records, and internal processes. Checking Whether the Amendment Applies The first step is to understand where the business stands under the amended law. Corpseed can review the organization’s activities, vendor relationships, and transaction structure to identify: Provisions that directly cover the business. Requirements that will apply only after commencement. Possible exposure to future Central or State notifications. Teams that may need to change their existing processes. This review can help a business focus on relevant provisions instead of applying the entire amendment to every transaction. Tracking Commencement Dates and New Rules The Act allows different provisions to begin on different dates. It also leaves several practical details to be addressed in future notifications and rules. These may cover registration forms, TReDS procedures, reporting formats, and the conduct of penalty proceedings. Corpseed can track these developments and explain how a new notification affects the business. This may include reviewing: Commencement notifications. Central and State implementing rules. Revised classification conditions. Prescribed forms and filing procedures. Reporting and record-keeping requirements. Assistance With MSME Registration The amendment describes memorandum filing as free and voluntary. Even so, registration may remain relevant for accessing government benefits and determining the supplier’s official address in a payment dispute. Corpseed can assist with: Checking the enterprise’s eligibility and classification. Reviewing the information required for registration. Preparing the filing on the notified digital platform. Checking existing registration details for errors or outdated information. Supporting permitted corrections and updates. Preparing for TReDS-Based Settlement Once the relevant provision becomes operational, covered Central Public Sector Enterprises and other notified entities may be required to route MSME invoice settlements through an authorized Trade Receivables Discounting System platform. The preparation process can go beyond just signing up for a platform. Purchase orders, invoice approval, vendor files, payment authorization, and accounting reconciliation may require coordination. Corpseed can review: The existing invoice-processing cycle. Controls used to identify MSME vendors. Purchase-order and invoice-acceptance procedures. Coordination between procurement, finance, and treasury teams. Differences between current systems and the notified TReDS process. Records showing that an invoice was routed and settled correctly. The final compliance process can be determined only after the relevant Government issues the prescribed rules and procedures. Reviewing Vendor Records Wrong category, MSME number, or location of the MSME will hamper the invoicing process and dispute resolution. Therefore, vendor details must be validated before starting the invoicing process. The checklist may include: Registration of MSME Classification of enterprise Registered business location Vendor statements Documents evidencing registration Vendor master records Procedure for supplier reclassification Reporting and Document Control The new clause mandates another disclosure requirement for invoices processed through TReDS. It is important to remember that this cannot be mistaken for the reporting requirement in Section 22 regarding unpaid invoices and interest payments. Corpseed can help identify the applicable reporting requirement, trace invoice figures to supporting records, and prepare internal checks for the responsible teams. The work may include: Mapping invoice data to the correct legal provision. Reviewing the records used to prepare a disclosure. Creating practical reporting checklists. Reconciling finance records with platform information. Improving coordination between finance and compliance personnel. Organizing Delayed-Payment Records A payment claim is easier to assess when the transaction file is complete. Missing purchase orders, delivery records, or written objections can create avoidable difficulties during mediation or arbitration. Corpseed can help organize records such as: Contracts and Purchase Orders. Delivery or Performance Certificates. Bills submitted for payment. Documentation that the bills have been received and accepted. Any objections put forward by the purchaser. Payment Terms Agreed Upon. Statements of amount outstanding. Letters between the supplier and purchaser. This service does not guarantee recovery or any outcome of the matter. Preparing for MSEFC Proceedings The amendment introduces defined periods for mediation, referral to arbitration, and the making of an arbitral award. Businesses may have less room for internal delay once a matter reaches the Micro and Small Enterprises Facilitation Council. Corpseed can assist with preliminary document review, organization of the dispute file, and identification of the applicable statutory dates. It can also help check the supplier’s registered address, which is relevant to jurisdiction under the amended provisions. Where a matter requires legal representation, interpretation of contested rights or case-specific legal advice, the business may also need to engage an appropriately qualified legal professional. Continuing Compliance Support The amended framework will develop through commencement notifications, Central rules, State rules, and platform procedures. A process designed before these instruments are issued may need to be revised later. Corpseed can continue monitoring verified regulatory developments and help the business update its records, reporting controls, and operating procedures when a relevant requirement changes. Speak With a Corpseed Compliance Specialist MSMEs, CPSEs, and other potentially affected organizations can approach Corpseed for support with applicability reviews, MSME registration, TReDS readiness, documentation, and regulatory monitoring. Corpseed provides filing, documentation, and compliance-coordination assistance. Registration, government approval, payment recovery, and the outcome of mediation, arbitration, adjudication, or court proceedings remain subject to the relevant authority and applicable law.

Subject

Summary: The DoT issued notifications of three TEC specifications for telecom equipment on 3 August 2026, and they were published in the Gazette of India on 6 August 2026. If your organization is engaged in the manufacture, import, or sale of IoT gateways, Fixed Wireless Access (FWA) customer-premises equipment, or underground telecom cables, the new notification directly impacts the technical standard for TEC certification of your products. In simple terms, a "TEC standard" is a technical rulebook. It specifies exactly which performance, safety, and quality requirements a piece of telecom equipment must meet before it can be tested, certified, and legally sold, imported, or deployed on an Indian telecom network. When DoT "notifies" a standard, that rulebook becomes the official reference point that testing labs and certification authorities use to check your product. Without a notified standard, a product category can sit in a grey zone where certification is slow, inconsistent, or simply not possible. For businesses, the practical takeaway is simple: if you make or import IoT gateways, FWA CPE, or the specific underground cable construction covered here, you need to confirm your certification paperwork references the correct, current standard number. Getting this wrong even on a technicality like an outdated standard reference can mean delayed shipments, held-up customs clearance, or a rejected certification application. Getting your documentation, testing plan, and certification strategy right the first time is exactly where experienced regulatory compliance support, such as Corpseed's TEC/MTCTE certification assistance, can save real time, cost, and back-and-forth with authorities. Key Highlights Issued under Section 19 of the Telecommunications Act, 2023 (44 of 2023), read with Rule 5 of the Telecommunications (Framework to Notify Standards, Conformity Assessment and Certification) Rules, 2025. Three standards have been formally notified for telecommunication equipment. Standard 1: TEC 33011:2026 Test Guide for IoT Gateway. Standard 2: TEC 21141:2026 Test Guide for Fixed Wireless Access (FWA) Customer Premises Equipment. Standard 3: TEC 68090:2026 Generic Requirements for Solid Polythene Insulated, Fully Jelly-Filled, Polythene-Sheathed Underground Telecom Cables. The standards take effect from the date of publication of the notification in the Official Gazette, i.e., 6 August 2026. This notification does not impose any additional time limit for compliance beyond the effective date noted above. These standards form part of India's wider certification regime (MTCTE), which applies to telecom equipment manufactured, imported, or used in India. Organizations that are already certified for comparable products are advised to confirm whether their existing standard reference remains relevant. The Regulatory Framework Applicable Act: The Telecommunications Act, 2023, which is the primary legislative framework governing telecom networks, spectrum, and telecom equipment in India. This Act largely replaces the colonial-era Indian Telegraph Act, 1885, as the cornerstone for telecommunication regulation. Applicable Regulations: Telecommunications (Framework to Notify Standards, Conformity Assessment and Certification) Rules, 2025. These regulations have been notified to establish a systematic approach to setting technical standards and ensuring compliance through conformity assessment. The regulations cover all stakeholders in the telecoms equipment chain: manufacturers, importers, laboratories, telecoms operators, and, by extension, consumers of such equipment. The regulations have formally repealed the previous Indian Telegraph (Amendment) Rules, 2017, which had governed the testing and certification of telecoms equipment for nearly a decade. However, the standards and certification criteria remain valid until a fresh notification under Section 19 of the Act repeals them, which is essentially what this 3 August 2026 notification does. Notifying Authority: Telecommunication Engineering Centre (TEC), the technical wing of the Department of Telecommunications, originally established in 1991 to develop and maintain technical standards for telecom equipment and networks in India. TEC also acts as the Designating Authority, appointing accredited Conformity Assessment Bodies (CABs), the labs authorised to test equipment and issuing the final TEC certificate once a lab's test report confirms compliance. How TEC Standards Are Classified: TEC organises its technical benchmarks into a few recognised categories, including Generic Requirements (GRs), baseline requirements applicable broadly to a product category, Interface Requirements (IRs), Service Requirements (SRs), and Test Guides, which specifically define the test methods and procedures used to check conformity. In this notification, two of the three standards (TEC 33011:2026 and TEC 21141:2026) are Test Guides. At the same time, the third (TEC 68090:2026) is a Generic Requirements document, meaning it sets the baseline technical benchmark for the cable type itself. At the same time, the two Test Guides define how conformity of the IoT gateway and FWA CPE products is actually verified in a lab. Legal Background: Under Rule 5 of the 2025 Rules, the Central Government, acting through TEC, is empowered to notify technical standards for defined categories of telecom equipment formally. Once notified in the Official Gazette, a standard becomes the binding reference document against which conformity assessment (testing and certification) is carried out for that equipment category, and it feeds directly into the MTCTE certification process. Scope: This notification covers three equipment categories: IoT gateways, FWA customer premises equipment, and a specific type of underground telecom cable. It does not change the certification process, application procedure, or fee structure; it only adds or updates the technical standards that testing labs and TEC will apply when assessing these product categories in the future. Industries Covered: Telecom equipment manufacturers, IoT hardware developers, fixed wireless broadband equipment vendors, telecom cable manufacturers, equipment importers, telecom infrastructure contractors, and telecom service providers who procure or deploy this equipment across their networks. What Has Changed? The notification formally brings three specific technical documents into force as official TEC standards, each tied to a distinct equipment category. Here is what each one covers, in plain terms: Standard Document Type Product Category What It Essentially Covers TEC 33011:2026 Test Guide IoT Gateway Defines how an IoT gateway device should be tested to confirm it meets the required performance and conformity benchmarks TEC 21141:2026 Test Guide Fixed Wireless Access (FWA) Customer Premises Equipment Defines how FWA customer-end equipment such as the wireless broadband receiver unit installed at a subscriber's premises should be tested for conformity TEC 68090:2026 Generic Requirements Solid Polythene Insulated, Fully Jelly-Filled, Polythene-Sheathed Underground Telecom Cables Lays down the baseline generic technical requirements this specific cable construction must meet A Test Guide, in practical terms, is the document that a testing lab follows, step by step, to determine whether a sample product passes or fails against the relevant benchmark. It typically defines the test setup, parameters checked, and pass/fail criteria for that product type. Generic Requirements, on the other hand, define the underlying technical specification the product itself must be built and manufactured to meet in this case, construction and performance requirements for the cable's insulation, jelly-filling, and sheathing. Previous position vs. new position: The notification text does not explicitly state that it withdraws or replaces an earlier version of a standard for these three categories it notifies them as the current applicable standards with effect from the Gazette publication date. If your product currently holds a certification referencing an older or interim standard for IoT gateways, FWA CPE, or this cable construction, it is worth confirming directly with TEC or a certification consultant whether the newly notified standard supersedes the one your existing certificate references, and whether retesting or a documentation update is required. Implementation Timeline Effective Date: The standards apply with effect from the date of publication of the notification in the Official Gazette, i.e., 6 August 2026. Transition Period: There is no provision for any transition period or grace period in this notification. This is generally the case with such standards notifications, which become immediately effective from the date of Gazette Notification. Applicability: This applies only to the three types of equipment mentioned: IoT gateways, FWA CPE and the specified underground telecom cable installation. This will not apply retroactively to other product categories. Action Required by Business: Manufacturers and importers of these three types of equipment should immediately verify their current TEC/MTCTE certificate status with respect to the notified standard numbers and confirm from the test laboratory/TEC whether retesting, submission of a fresh application for certification or just an update on the document mentioning the new standard number is required for future/new applications. Fresh Applications: Any MTCTE application received in these product categories after 6 August 2026 should cite the newly notified standard as the relevant benchmark. Why Was This Implemented? Standards notifications like this one are a routine but structurally important part of how India's telecom certification system stays current with technology and market needs. The broader legal framework under Section 19 of the Telecommunications Act, 2023 establishes testing and certification mandates for telecom equipment used across Indian networks, with the underlying goal of strengthening security, interoperability, and quality control throughout the sector. The certification framework's core objective is to ensure that telecom equipment and services conform to notified technical and security requirements through a formal conformity assessment process one that supports accountability, user safety, and the reliability of telecom infrastructure at large. The cable standard, TEC 68090:2026, supports consistent quality benchmarks for underground telecom cable infrastructure, a foundational, if less visible, part of network reliability. Underground cables of this construction (solid polythene insulated, fully jelly-filled, polythene sheathed) are widely used for physical protection against moisture and mechanical stress in buried telecom lines. Hence, a current Generic Requirements standard helps ensure a consistent baseline of quality across manufacturers supplying this cable type to network operators and infrastructure projects nationwide. More broadly, keeping TEC standards current also supports India's ease-of-doing-business and interoperability goals; manufacturers benefit from having an unambiguous, up-to-date reference for design and testing, rather than relying on outdated or draft specifications that can create uncertainty during certification. Impact on Businesses Manufacturers (IoT gateways, FWA CPE, telecom cables): Please test your products to comply with the new TEC standard numbers to obtain TEC certification in the future, and update internal quality documents, design validation checklists, and supplier specifications to reference the updated standard. Importers: If you import IoT gateways, FWA CPE, or specific types of cable intended for use in India, you must ensure they conform to TEC standards as part of MTCTE certification to obtain import approval and sell them. Any references to an outdated standard number on import papers may lead to delays. Exporters: Even though the destination country determines export regulations, companies operating in India that export products to other countries may improve their brand image by aligning with current TEC standards, since many Indian companies do business with certain international buyers. Brand Owner / OEM: Even if the product is produced for you by a subcontractor, it must include proper certification referencing the appropriate, up-to-date standard. MSMEs and Startups: Smaller IoT hardware startups and FWA equipment makers, who often operate on tighter timelines and budgets than large OEMs, should factor the cost and lead time of testing against the new standard into their product launch and go-to-market planning, ideally well before a launch date is locked in. Large Enterprises: While larger firms with their own testing facilities or associations with certified laboratories are likely to find it easier to adapt to this change, they must ensure that their certification status is up to date. Telecom Service Providers / Network Operators: Procurement teams sourcing FWA CPE or underground cable for network rollout and expansion projects should confirm that vendor equipment carries certification referencing the currently applicable standard, to avoid procurement or deployment delays. Distributors / Retailers / Traders: Should confirm with their suppliers that stock currently being sold or planned for future orders carries valid, current TEC certification, rather than relying on certificates issued against a superseded standard. Service Providers Installing or Maintaining Equipment: Installation and field service teams working on FWA CPE or IoT gateway deployments should be aware that newly procured units are expected to carry certification to the current standard, which may be relevant during network audits or compliance checks. Although the notification does not impose different financial sanctions on businesses that are not in compliance, they can consult the enforcement provisions in the Telecommunications Act, 2023, and the 2025 Rules for sanctions on conducting business with uncertified or non-compliant equipment. The more comprehensive enforcement provisions in the 2025 Rules allow for the issuance of notices to correct non-compliance within a set period, and any further non-compliance may result in suspension of service or seizure of the uncertified equipment. How Businesses Can Approach Compliance? Identify applicability: Confirm whether your product falls under the IoT Gateway, FWA CPE, or the specified underground cable category covered by this notification. Check the current certification status: If you already hold a TEC/MTCTE certificate for the product, verify which standard number it currently references and compare it against TEC 33011:2026, TEC 21141:2026, or TEC 68090:2026, as applicable. Coordinate with an accredited test lab:  testing against the newly notified standard will typically be needed for new certification applications, and may be needed for renewals or updates to existing certificates. TEC designates specific Conformity Assessment Bodies (CABs) authorised to conduct this testing. Prepare or update your MTCTE application:  submit a fresh application, or update an existing one, through the applicable DoT/TEC online certification portal, referencing the correct standard and attaching the relevant test reports. Review Essential Requirements carefully:  MTCTE certification is assessed against defined Essential Requirements for each product category, covering aspects such as network integrity, user safety, and radio-frequency emission limits where applicable align your product documentation accordingly. Maintain organised documentation:  keep test reports, technical files, design records, and certificates well organised and easily accessible, since these are typically required again at renewal or during compliance audits. Track certification validity and renewal timelines:  Certificates are generally issued for a defined validity period; track renewal dates proactively so certification does not lapse mid-sales cycle. Update supply chain and vendor documentation: If you are a brand owner or distributor relying on third-party manufacturers, request updated compliance documentation from your suppliers that references the current standard. Common mistakes businesses should avoid: mentioning the number of a superseded standard within a new certification request automatically assuming that the validity of an old certificate continues even after a new standard notification for the same product class is issued waiting until right before the launch of the product to carry out tests and not disseminating information about new standards within the organization. Benefits for Businesses Conforming to the new standards has multiple tangible benefits apart from compliance in itself: Continuous access to the market:  The products that comply with the current standard are not subject to detention at customs, sales stoppage, or application denial due to out-of-date information. Lower risk of penalties or enforcement measures:  Complying with the current standard reduces the likelihood of receiving notices, suspensions, or seizures under the certification scheme's general enforcement rules. Stronger buyer and partner confidence:  A current, correctly referenced TEC certificate signals to distributors, network operators, and B2B buyers that your product meets the latest recognised benchmark. Smoother government and enterprise tenders:  Many public-sector and large enterprise procurement processes require current, valid certification as a mandatory qualifying criterion. Operational efficiency:  Aligning early avoids the scramble and rushed testing that often happens when a certification gap is discovered late, close to a shipment or launch deadline. Better long-term product planning:  Having a clear, current technical benchmark makes it easier to plan design validation and quality assurance processes with confidence, rather than working against an outdated or ambiguous reference. Right Decision or Additional Compliance Step? This notification is best understood as a routine technical update rather than a sweeping new regulatory burden. It does not introduce a new licensing regime, a new fee structure, or a fundamentally new compliance process it simply fills in or refreshes the specific test/requirement standard for three equipment categories that were, in principle, already expected to go through certification under the existing MTCTE framework. For companies that are familiar with MTCTE and TEC certification, the only issue addressed by this notification is a technical one: ensuring the correct standard is referenced. This is not an issue that would require much time or restructuring. For newer entrants, particularly IoT hardware startups and FWA equipment manufacturers who may previously have been operating without a clearly defined, up-to-date test benchmark for their category, this notification arguably reduces uncertainty. Having an explicit, current standard to design and test against can make product planning easier and more predictable than operating under an unclear, outdated, or draft requirement, even though it does require upfront testing and documentation. However, the primary issue faced by companies is not the content of the requirement but the timing and awareness of it, to ensure that the update is detected early enough to be incorporated into any certification applications in progress or soon to be submitted. Business Opportunities Created Beyond the immediate compliance task, a clear and current standard can open up practical opportunities for businesses positioned to act on it: Faster, more predictable certification for new product launches- A defined, current standard reduces ambiguity for companies developing new IoT gateway or FWA CPE products, supporting more predictable go-to-market timelines. Stronger positioning in government and infrastructure tenders:  Telecom infrastructure and smart-city projects that require current TEC-certified equipment create demand that compliant manufacturers and suppliers are well placed to capture. Expansion into IoT and fixed wireless hardware manufacturing:  As India's IoT and FWA broadband segments continue to grow, having early, correct certification against the current standard can be a competitive advantage when pitching to network operators and system integrators. Import and distribution opportunities: International manufacturers seeking to enter or expand in the Indian market now have a clear, current benchmark to certify against, which can support faster market entry when handled correctly. Underground cable supply opportunities: Telecom operators and infrastructure contractors expanding wired network capacity will require cable that meets the current Generic Requirements standard, creating a clear specification for cable manufacturers and suppliers to build against. Value in specialised compliance consulting: The recurring need to track, interpret, and act on TEC standard updates across multiple product lines creates ongoing demand for dedicated regulatory compliance support, particularly for manufacturers managing certification across multiple equipment categories simultaneously. Why Choose Corpseed? Keeping track of every TEC standard update, correctly matching it to your specific product category, and managing the full MTCTE application process can be time-consuming for manufacturers and importers focused on building and selling products, not on chasing paperwork or monitoring Gazette notifications. Corpseed's regulatory compliance team tracks these notifications as they are published, helps identify precisely which standard applies to your product based on its technical specifications, and coordinates with accredited testing labs to plan the testing process efficiently. On the documentation side, Corpseed assists with preparing and filing MTCTE applications, organising technical files and test reports, and managing renewals so certificates don't lapse unexpectedly. For businesses managing certification across multiple product lines IoT gateways, FWA CPE, cables, or other MTCTE-covered categories having a single point of coordination for tracking standard updates and managing filings can meaningfully reduce internal time and risk, while keeping the process transparent and predictable from application to approval. Corpseed's Core Message Missing a standard update or filing a certification application under the wrong reference number can quietly translate into real business costs: delayed shipments, products held up at customs, rejected applications, or missed tender eligibility. If your business manufactures or imports IoT gateways, FWA CPE, or underground telecom cables of the type covered here, it is worth confirming today whether your current or planned certification aligns with TEC 33011:2026, TEC 21141:2026, or TEC 68090:2026. Rather than treating this as a routine detail to handle later, address it now while the notification is fresh to reduce the risk of it becoming an urgent, deadline-driven problem down the line. Corpseed's compliance team can conduct a quick applicability check for your specific product, flag exactly which documentation or testing updates are needed, and manage the certification process end-to-end, so your team can stay focused on the product itself. Conclusion This notification updates the technical standards landscape for three telecom equipment categories: IoT gateways, FWA customer premises equipment, and a specific underground telecom cable construction under the framework established by the Telecommunications Act, 2023 and the 2025 Rules governing standards, conformity assessment, and certification. It takes effect from 6 August 2026, with no separate transition period stated in the notification text. For businesses in this space, the required action is clear: confirm the applicable standard reference for your product, check it against your current certification status, and align your TEC/MTCTE documentation and testing plan accordingly to avoid avoidable delays in sales, imports, or tender eligibility. While this update is administrative in nature rather than a major regulatory overhaul, timely action matters certification gaps are far easier to resolve proactively than after a shipment is held up or an application is rejected. For a quick applicability check on your specific product, or for end-to-end support with TEC standard alignment and MTCTE certification, reach out to Corpseed's compliance team.

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Summary: Pan masala is provided with a special packaging entry by the Food Safety and Standards Authority of India. Food Safety and Standards (Packaging) Amendment Regulations, 2026, include pan masala in Schedule IV of the Food Safety and Standards (Packaging) Regulations, 2018. The new entry says that paper, paperboard, cellulose, and other naturally derived materials used for pan masala must be free of plastic. They must also be free from aluminium foil and metalized layers. Tin and glass containers are included as other packaging choices. The notification does not state a separate grace period. Pan masala manufacturers, packers, brand owners, importers, and packaging suppliers should therefore examine every layer and component of their packaging. Although these rules are brief, their impact on businesses could be more than expected. The bag might appear to be made of paper but actually be made of plastic, aluminium, or metallised films. Businesses require facts about materials, not assumptions based on appearance. Notification at a Glance Particular Verified detail Issuing authority Food Safety and Standards Authority of India Governing law Food Safety and Standards Act, 2006 Regulations amended Food Safety and Standards (Packaging) Regulations, 2018 Schedule amended Food Safety and Standards (Packaging) Regulations, 2018 Product covered Pan masala Main stakeholders Manufacturers, packers, brand owners, importers and packaging suppliers Main development Addition of plastic-free, foil-free packaging choices for pan masala Transition period Not expressly specified Separate compliance deadline Not expressly specified; the amendment states that it starts on publication The Regulatory Framework Food Safety and Standards Act, 2006 The Food Safety and Standards Act, 2006, is India’s main central law for food safety. It created the FSSAI and gave it the authority to make food regulations. The Act covers many matters, including how food is made, stored, distributed, sold, and packaged. The 2026 notification refers to section 92 of the Act. Section 92 provides the regulation-making process. The final notification states that FSSAI used the power under section 92(2)(k), with the previous approval of the Central Government, to amend the Packaging Regulations. In simple words, FSSAI did not issue this as an informal suggestion or a news release. It issued amendment regulations in the Official Gazette under the powers conferred by the Act. Food Safety and Standards (Packaging) Regulations, 2018 The Packaging Regulations establish general standards for packaging materials used to package food products. According to these regulations, primary packaging materials are materials that come into direct contact with the food product. Secondary packaging comes around the primary pack but does not come into direct contact with the food product. The regulations require food-contact packaging to be food-grade. Packaging must suit the food, storage conditions, filling and sealing equipment, transport conditions, and normal mechanical, chemical, or heat stress. Food must also be packed in a clean, hygienic, and tamper-proof package. Another important rule concerns evidence. The official FSSAI compendium states that a food business operator must obtain a certificate of conformity from a National Accreditation Board for Testing and Calibration Laboratories (NABL)- accredited laboratory for packaging that directly touches food or is likely to touch it. Schedule IV gives a product-wise list of suggestive packaging materials. The base regulations describe this as an indicative list and generally do not preclude the use of other materials that meet the specified standards. The new pan masala entry, however, uses direct words such as “shall be free from any plastic.” This means businesses should not read the word “suggestive” as permission to ignore the express plastic-free and foil-free conditions. Where there is uncertainty, a written legal or regulatory view is safer than a broad assumption. Connection with the Plastic Waste Management Rules, 2016 The amendment does not work alone. It expressly says that clauses (f) and (i) of Rule 4(1) of the Plastic Waste Management Rules, 2016, also apply. Rule 4(1)(f) says that sachets made of plastic material must not be used for storing, packing, or selling gutkha, tobacco, and pan masala. Rule 4(1)(i) is wider. It states that plastic material in any form, including Vinyl Acetate-Maleic Acid-Vinyl Chloride Copolymer, must not be used in any package for gutkha, pan masala, or tobacco. This is a vital point. The environmental rules already contained a plastic restriction. The FSSAI amendment now includes a clear entry for pan masala material in the food-packaging schedule and expressly links it to those environmental rules. The Plastic Waste Management Rules also state that Rule 4 export exemption does not apply to units packaging gutkha, tobacco, and pan masala. Businesses should therefore avoid assuming that an export order automatically removes the packaging restriction. What Has Changed? The change in Schedule IV is directly caused by the introduction of Serial Number 11 for pan masala. This includes three interrelated aspects: approved material categories, excluded material categories, and the link to the Plastic Waste Management Rules. Addition of Pan Masala to Schedule IV Before this amendment, the 2025 version of the FSSAI Packaging Regulations listed ten product categories in Schedule IV. Pan masala did not have its own entry in that version. The amendment inserts pan masala after Serial Number 10. This makes the expected packaging direction easier to find within the FSSAI food-packaging framework. A manufacturer no longer needs to look only at a general environmental ban to understand the basic material position. Permitted Packaging Materials The new entry names the following material categories: Paper Paperboard Cellulose Other naturally derived materials Tin containers Glass containers Paper, paperboard, cellulose, and other naturally derived materials are not approved without conditions. The notification says these materials must be free of any plastic. It also says they must not contain aluminium foil or metallised layers. A paper pouch with a hidden polyethylene coating may fail the stated condition. The same concern can arise when a paper pack contains a polyester layer, a synthetic laminate, or a metallised film. The outside appearance of a package is therefore not enough to prove compliance. Tin and glass are named as container choices. These containers must still meet the general FSSAI rules on food-grade quality, cleanliness, suitability, sealing, and safe food contact. For example, choosing a glass jar does not eliminate the need to assess its closure, seal, and any component that may come into contact with the product. Prohibited Packaging Materials and Components The notification says the naturally derived material must be free from any plastic, including but not limited to: Polyethylene, often called PE Polypropylene, often called PP Polyester Polyvinyl chloride, or PVC Any synthetic polymer Copolymers Laminates containing prohibited plastic Aluminum foil Metalized layers The words “including but not limited to” matter. The list provides examples, but it is not exhaustive. A business cannot treat an unlisted plastic as allowed simply because its chemical name does not appear in the notification. The phrase “any plastic” also makes it risky to assume that bio-based, biodegradable, or compostable plastic is acceptable. Such material may still legally be a plastic. The amendment does not create a clear exception for it. Does the Restriction Cover Every Packaging Component? The entry speaks about material used for pan masala packaging and also refers to plastic material “in any form” through Rule 4(1)(i). A safe compliance review should therefore examine the whole pack, including: The main pouch, jar, or tin Inner linings and barrier layers Heat-seal coatings Plastic-based adhesives Lids, caps and closure systems Inner seals and membranes Transparent windows Labels and shrink sleeves Printing coatings and varnishes Tamper-evident parts The notification does not explain every small component separately. It also does not clearly state how its new Schedule IV wording applies to secondary transport material that never forms part of the consumer pack. Those questions should be assessed against the exact pack design, the general Packaging Regulations, and the Plastic Waste Management Rules. Earlier Position vs New Position Earlier verified position New position from 10 August 2026 Plastic was already barred for pan masala packaging under the Plastic Waste Management Rules. Schedule IV had no separate row for pan masala. Serial Number 11 now names natural material, tin, and glass options and expressly excludes plastic, aluminum foil, and metalized layers from the natural-material format. The amendment therefore makes the material direction clearer within the FSSAI framework. It does not mean that plastic was freely allowed before 10 August 2026. Scope and Applicability Products and Businesses Covered The new entry expressly covers pan masala. It does not create a new product definition. Businesses should check the product standard, ingredients, label, and FSSAI license before deciding whether a similar product is covered. Supari or mouth freshener should not be included only because it is sold in a small pouch; equally, changing a product name does not change its true legal classification. These are the parties who are directly involved: manufacturers, contract packers, brand owners, importers, and packaging suppliers. Distributors and retailers may also require stock information. Imported pan masala intended for India must comply with India's packaging regulations. The Plastic Waste Management Rules are also important for exporters. Their general Rule 4 export exemption does not extend to units packaging gutkha, tobacco, and pan masala. Implementation Timeline and Norms Notification, Publication and Effective Dates The draft notification was released on 28 April 2026. The notification date is 7 August, whereas the gazette date is 10 August 2026. Since the amendment will commence from the date of publication, 10 August 2026 will serve as the date of operation. No other implementation date is stated in the notification. Is a Transition or Grace Period Available? There is no explicit mention of any transition, grace period, or phased implementation. Redesign of the package may be difficult, but business difficulty, per se, does not constitute a legal extension. Existing Packaging and Finished Goods There is no information in the notification on how much older packaging, produced before 10 August, can be used. The notification does not provide a definite rule for the sell-through of existing packaged goods. Businesses should segregate unused packaging materials, WIP, factory and market stock, and take a document-specific approach. Why Was This Amendment Implemented? Closing the Gap Between Paper Appearance and Actual Composition The Plastic Waste Management Rules have already banned plastic packaging for pan masala. In practice, a pack described as “paper-based” can still be a mixed structure. It may contain a plastic barrier, a heat-seal coating, a synthetic adhesive, aluminium foil, or a metallised layer. A 2026 Bureau of Indian Standards innovation challenge explained that manufacturers had shifted to multilayer paper-based laminates, but these small mixed-material sachets remained hard to collect, separate, and recycle. It also identified the continued use of plastic-based adhesives and heat-seal coatings as a concern. The FSSAI amendment gives businesses a clearer material direction: natural material must actually be free from plastic, foil, and metalized layers. Waste and Litter Concerns Small sachets are light and easily scattered. Their size makes collection difficult. When several materials are bonded together, separation and recycling become harder. Such packs can escape normal waste systems and become litter in streets, drains, fields, and water bodies. The final notification does not include a detailed statement of reasons. The waste explanation should therefore be understood as part of the verified policy context, not as extra wording inserted into the legal clause. Promotion of Workable Alternatives The amendment does not merely list banned materials. It also names paper, paperboard, cellulose, other naturally derived materials, tin, and glass. This gives manufacturers a starting group of alternatives. The hard part is performance. Pan masala packaging often needs moisture protection, aroma retention, seal strength, and enough shelf life for distribution. A truly useful alternative must align with environmental goals while keeping food safe and stable. Impact on Businesses Impact on Pan Masala Manufacturers Manufacturers need the exact construction of every pack. “Paper pouch” is too broad. Quality and procurement teams need layer-wise data, while production teams must check whether the material fills and seals safely on existing equipment. Impact on MSMEs MSMEs may face a heavier short-term adjustment because they buy smaller quantities and may have fewer packaging experts. They should not accept an “eco-friendly” claim without a composition statement and suitable evidence. Impact on Packaging Suppliers Suppliers now have a reason to develop plastic-free, foil-free barriers that still control moisture and aroma. Clear layer information and reliable evidence will matter more than labels such as “green laminate.” Cost and Supply-Chain Impact The cost may be due to factors such as research, testing, changes in machinery or suppliers, and even stock loss. The use of tin and glass packing materials might also contribute to weight, storage, and damage costs. There will be no cost associated with the notification. The cost may depend on the type of material used, pack size, quantity, machine, and shelf life. How Businesses Will Achieve Compliance Step 1: Confirm Product Classification Check the ingredients, food standards, FSSAI license, and label to determine whether the product is classified as pan masala. Step 2: Complete Package Analysis Prepare a bill of materials identifying all substrates, coatings, adhesives, seals, caps, labels, etc. Do not limit yourself to the substrate only. Step 3: Identify Prohibited Material Check for the presence of polyethylene, polypropylene, polyester, PVC, other polymers, copolymers, plastic laminates, aluminum foils, metallizations, etc. Maintain the status of "unknown" for each material until identification. Step 4: Selection of Alternative Material Narrow down your selection to paper, paperboard, cellulose, natural material, tin, glass, etc. Check the moisture resistance, aroma, strength, sealing, storage, and transport conditions. The cheapest material would be useless if it affects the product quality. Step 5: Confirming the Supplier A signed composition declaration and technical data sheets for plastic, foil, and metallization must be requested. All papers must be confirmed against the specific grade. Inform us of any alteration in the material. Step 6: Testing and Validation Obey FSSAI guidelines for testing and get a certificate of compliance for the packaging material that comes into direct contact. Testing can be carried out for migration, smell, seal strength, leakage, moisture, aroma, transport, and shelf life. Distinguish between mandatory testing and testing associated with product development. Step 7: Run Machine Trials Conduct machine trials with the material at normal speed and note any tearing, poor feeding, low seal strength, and rejection rate. Train the operator regarding the parameters. Step 8: Control Inventory Reject unknown material, separate the old and new materials, and associate approved packaging codes with the specific product and line. Step 9: Update Internal Controls Update purchase specifications, the approved supplier list, incoming inspection, change management, and allocate responsibilities to the regulatory, purchasing, quality, engineering, and warehouse departments. Documents and Evidence Businesses Should Maintain There is no specific requirement for any documents on pan masala under the notification. In line with the Packaging Regulations, it is necessary to provide a conformity certificate for the food contact package. The required internal documents will be: Packaging bill of material Composition declaration and technical data sheet of supplier Conformity, food contact, and migration report Shelf life and machine trial report Purchase specification and vendor approval form Change control, batch record, and packaging code.  Mandatory and recommended controls need to be segregated. It needs to be identified as per the actual commercial grade. The generic brochure is poor evidence because it doesn't show the actual structure purchased. Benefits for Businesses Full material maps mean the company will have greater control over changes from suppliers. Specifications prevent the company from getting an incorrectly described laminate. A package that is truly free of plastics might help the company establish a positive image, if the claims are true. The need for good alternatives can drive innovation and collaboration with suppliers. Trackable decisions will allow the company to inspect the process and conduct internal audits. Not all of these advantages will necessarily be achieved. Challenges and Cost Implications The biggest technical challenge will be replacing the plastic or foil without exposing the contents to moisture, while maintaining its smell and ensuring a good seal. Metal and glass packaging can be highly protective, yet more expensive and heavy. Glass packaging can be breakable. Metal containers will require special closure and analysis when handling corrosive products. Paper and cellulose packaging can be lightweight; however, it might be hard to design a plastic-free barrier and heat-sealing system. The lack of additional time before changes raises certain expectations, especially for MSMEs and companies with stockpiles. The right response is not to lower food safety. It is to redesign the package with legal, technical, and production teams working together. Is This the Right Decision or an Additional Burden? The amendment has a valid environmental purpose, but it also creates practical and financial challenges. The following table presents a balanced assessment. Assessment area Why the decision makes sense Additional burden on businesses Balanced view Environmental protection Plastic-free packaging can reduce difficult-to-collect and difficult-to-recycle waste. Alternative materials may still require technical development and proper disposal systems. The environmental goal is reasonable, but the alternative must work throughout its full life cycle. Clearer packaging rules The amendment makes it clear that paper packaging cannot contain hidden plastic, aluminium foil or metallised layers. Businesses must examine every coating, adhesive, barrier, seal, and closure. Clear rules reduce confusion, but FSSAI guidance on smaller packaging components would help. Packaging innovation The rule can encourage the development of paper, cellulose, tin, glass, and other suitable alternatives. New materials may not yet be widely available or affordable. Innovation may create long-term value, but businesses need scalable and cost-effective solutions. Food safety and quality Businesses are encouraged to select packaging that is both compliant and food-grade. Plastic-free materials may face problems with moisture, aroma retention, sealing, and shelf life. Environmental compliance should not weaken food safety or product quality. Proper testing remains essential. Cost of compliance Better packaging controls can improve supplier management and material traceability. Manufacturers may face costs for testing, machinery, supplier development, and packaging conversion. Larger businesses may adjust faster, while MSMEs may need technical and financial support. Implementation period Immediate application can accelerate the move toward compliant packaging. The notification does not expressly provide a grace period or phased implementation plan. A reasonable transition period could have reduced disruption without weakening the regulatory objective. Existing stock Immediate application discourages continued use of potentially non-compliant packaging. The notification does not clearly explain how unused packaging and already-packed goods should be treated. Written clarification on old stock and sell-through conditions would improve consistency. Overall business impact Early compliance may improve reputation and create a market for sustainable packaging. Short-term costs, material shortages, and production changes may affect business continuity. The decision is justified in purpose, but its success depends on clear guidance, affordable alternatives, and practical support. Balanced Conclusion This amendment is not just an advantage or disadvantage. The environmental goals of this amendment are justified because it tackles hidden plastics and packaging waste that are difficult to manage. However, manufacturers will pay more due to costs, technology issues, and uncertainty about current stock. We should get additional clarity from FSSAI on packaging components, evidence, old stock, and implementation. MSMEs might require assistance with testing and materials. Business Opportunities Created The modification can drive demand in the entire packaging industry. Paper and Cellulose Materials without Plastic Companies can manufacture paper and cellulose materials that regulate moisture and odour without using any plastic. Testable claims have to be made. Packaging Using Tin and Glass Containers Firms can produce small, light, and safer tin and glass containers. Designing closures will still be critical. Testing and Technical Assistance Laboratories can experience increased demand for food contact, material, barrier, seal, and shelf-life testing when using proper techniques. Machinery and Retrofitting Equipment manufacturers can provide sealing and filling equipment or adapt machines to handle natural materials. Compliance and Supplier Services Packaging audit, supplier assessment, legal validation, and change management services will also be needed. The biggest business opportunities are those that meet three requirements: legal compliance, food safety, and feasibility of mass production. Risks and Consequences of Non-Compliance There is no specific penalty prescribed for pan masala under the 2026 notification. Businesses should not quote any penalty amount as a general rule, since violations must be assessed under the FSSA and environmental laws, taking into account the specific circumstances of each case. These include questions that may arise during inspections and product testing, the inability to shift stock, decisions on product withdrawal, conflicts with suppliers, production halts, and damage to brand reputation. There may be other risks associated with environmental deception. Inadequate information is the biggest risk to controls. If the supplier designates a packaging structure as ‘paper’ and does not inform you of its plastic coating, the end package will not meet the new requirement. Documentation and change controls are thus fundamental controls. Practical Compliance Checklist Ensure that the product is properly classified as pan masala. Document the packaging structure completely. Check for layers made of polyethylene, polypropylene, polyester, and PVC. Check for other synthetic polymers and copolymers. Check for aluminium foil and metallised layers. Review coatings, adhesives, seals, caps, and labels. Obtain exact supplier composition information. Confirm applicable food-contact requirements. Obtain the applicable certificate of conformity. Complete suitable safety and performance tests. Validate shelf life and product quality. Run the material on the actual packing machine. Separate uncertain old packaging and finished stock. Revise purchase and supplier requirements. Train regulatory, purchasing, quality control, and manufacturing staff. Maintain batch, material, and change-control documentation. Examples of controls that can be implemented include the bill of materials, machine trial report, and internal checklists, unless another requirement or license condition necessitates their use. The requirement for a certificate of compliance arises from the general FSSAI Packaging Regulations for food contact packaging. How Corpseed Can Help Corpseed helps pan masala manufacturers, importers, brand owners, and packaging companies understand and follow the new FSSAI packaging requirements. The support is based on the actual product, the materials used in its packaging, and the compliance gaps that need to be addressed. 1. Checking Whether the New Rules Apply Check whether the product is a pan masala product according to the law. Determine which FSSAI packaging regulations pertain to the product and business. Describe what is required and what needs further clarity. 2. Reviewing the Complete Packaging Structure Check every part of the packaging, including its layers, coatings, adhesives, seals and closures. Find any plastic, aluminium foil, or metallised material hidden inside the package. Assess whether the proposed packaging material meets the amended requirements. 3. Finding Compliance Gaps Compare the existing packaging with the new FSSAI requirements. Identify materials, records and business processes that need to change. Prepare a clear action plan to correct the identified gaps. 4. Checking Supplier Documents Review material declarations, technical data sheets and other documents provided by packaging suppliers. Confirm that the documents relate to the exact packaging material being purchased. Identify missing, incomplete or unclear information about the material’s composition. 5. Supporting Packaging Testing Help the business understand which food-contact and packaging tests may be relevant. Coordinate with suitable laboratories for the required testing. Organise conformity certificates, test reports and supporting records. 6. Improving FSSAI Records and Internal Controls Review the relevant FSSAI licence and existing compliance records. Prepare simple checklists for checking and approving packaging materials. Improve records so that each packaging material can be traced to its supplier, product and batch. 7. Providing Ongoing Regulatory Support Monitor new FSSAI packaging notifications, directions and clarifications. Review proposed packaging changes before they are used in commercial production. Help the business keep its compliance documents complete, current and properly organised. Professional support cannot replace correct supplier information or guarantee a regulatory outcome. However, it can help businesses understand their obligations, identify packaging risks, and maintain reliable evidence before starting commercial production. Pan masala manufacturers, importers, and brand owners may use Corpseed’s FSSAI compliance services for a document-based review of their packaging and implementation plan.